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Chilean–Peruvian maritime dispute

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Maritime Dispute (Peru v. Chile)
Map annexed to the Court's judgment showing the maritime boundary between Chile and Peru
CourtInternational Court of Justice
Full case name Case concerning the Maritime Dispute between the Republic of Peru and the Republic of Chile
DecidedJanuary 27, 2014
CitationI.C.J. Reports 2014, p. 3
Court membership
Judges sittingPresident Peter Tomka; Vice-President Bernardo Sepúlveda Amor; Judges Hisashi Owada, Ronny Abraham, Kenneth Keith, Mohamed Bennouna, Leonid Skotnikov, Antônio Augusto Cançado Trindade, Abdulqawi Ahmed Yusuf, Xue Hanqin, Joan Donoghue, Giorgio Gaja, Julia Sebutinde, Dalveer Bhandari; Judges ad hoc Gilbert Guillaume (Chile) and Francisco Orrego Vicuña (Peru)

Perú v. Chile (also called the Chilean–Peruvian maritime dispute or the Case concerning the Maritime Dispute between the Republic of Peru and the Republic of Chile) was a case in public international law concerning a long-standing disagreement between Peru and Chile over the location of their maritime boundary in the Pacific Ocean. Peru maintained that no treaty had ever fixed a maritime boundary between the two countries and asked for an equitable division of the overlapping 200-nautical-mile zones claimed by each state; Chile maintained that the boundary had already been settled, running along the parallel of latitude that meets the coast at the end of the two countries' land border, by agreements the two countries signed together with Ecuador in 1952 and 1954.

On January 16, 2008, Peru submitted the dispute to the International Court of Justice (ICJ) in The Hague. After six years of written and oral proceedings, the Court delivered its judgment on January 27, 2014. It found that a maritime boundary along the parallel of latitude passing through Boundary Marker No. 1 had indeed been tacitly agreed by the parties, but only for a distance of 80 nautical miles from the coast; beyond that point, the Court drew a new boundary running southwest along a line equidistant from the coasts of the two countries out to 200 nautical miles. The ruling gave Peru sovereign rights over roughly 50,000 square kilometers (19,300 square miles) of the Pacific Ocean that Chile had previously treated as part of its exclusive economic zone or as high seas, while confirming Chile's rights over the waters closest to its own coast, including most of the area's richest fishing grounds.[1][2] Both governments pledged to abide by the decision, and representatives of the two countries signed an act fixing the precise geographic coordinates of the new boundary on March 25, 2014.[3]

Background

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Treaties of Ancón and Lima (1883–1930)

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The War of the Pacific left the land border between Chile and Peru unsettled for nearly half a century. The 1883 Treaty of Ancón and the definitive 1929 Treaty of Lima fixed the land boundary, providing that it would run from a point on the coast to be called "Concordia," located ten kilometers north of the bridge over the Lluta River, and would be demarcated on the ground by a mixed boundary commission.[4] A joint Chilean–Peruvian commission carried out the physical demarcation in 1930. Because the exact point where an arc drawn ten kilometers from the Lluta bridge met the shoreline lay in terrain that could be washed away by the sea, the commission's final act of July 12, 1930, placed the physical marker — "Hito No. 1" — about 180 meters inland from the water's edge, at coordinates the commission described as located at the "seashore" (orilla del mar). This distinction between the notional coastal terminus of the boundary (which Peru later called the "Concordia Point") and the physical marker inland from it (which Chile treated as the terminus) became one of the central technical disputes between the two countries.

1947 unilateral declarations

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Following a September 1945 proclamation by U.S. President Harry S. Truman asserting American jurisdiction over resources of the continental shelf, several Latin American governments issued similar unilateral claims. On June 23, 1947, Chilean President Gabriel González Videla declared national sovereignty over the sea adjacent to Chile's coasts out to 200 nautical miles, without prejudice to the legitimate rights of other states on a reciprocal basis. On August 1, 1947, Peruvian President José Luis Bustamante y Rivero issued a similar declaration by Supreme Decree No. 781, asserting sovereignty and jurisdiction over the sea adjacent to Peru's coasts out to 200 nautical miles, while explicitly reserving the right to modify the demarcation of these zones in light of future discoveries and national interests.

The 1952 Declaration and the 1954 agreements

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On August 18, 1952, Chile, Ecuador, and Peru signed the Declaration of Santiago (Declaración sobre Zona Marítima) at a conference on the exploitation and conservation of the marine resources of the South Pacific. The declaration proclaimed each state's exclusive sovereignty and jurisdiction over the sea within 200 nautical miles of its coast and provided that, in the case of island territories, the 200-mile zone of an island less than 200 miles from another signatory's general maritime zone would be limited by the parallel of latitude passing through the point where the land boundary between the two states meets the sea. Peru later argued that this island clause, inserted at Ecuador's request because of its offshore islands, was the declaration's only reference to a parallel boundary and had no bearing on the continental coast shared by Peru and Chile, where no islands lie. Chile, for its part, argued that the clause simply reaffirmed a general rule that adjoining states' zones were already divided by the parallel.

To curb disputes with small-scale fishermen who often strayed across the frontier, the three countries signed the Special Maritime Frontier Zone Agreement in Lima on December 4, 1954. It established a "special zone," beginning 12 nautical miles from the coast and extending 10 nautical miles on either side of "the parallel that constitutes the maritime boundary between the two countries," within which the accidental presence of small vessels of one country in the waters of the other would not be treated as a violation. Peru later characterized the accord as a practical fisheries measure rather than a boundary treaty, while Chile argued that the text's own wording presupposed the prior existence of a maritime boundary running along the parallel.

The 1968–1969 lighthouse arrangements

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Following complaints about the seizure of fishing vessels near the frontier, Peru and Chile in 1968 agreed to build lighted markers to help fishermen visually locate "the parallel of the maritime boundary originating at Boundary Marker No. 1." Technical delegations from both countries signed acts in April 1968 and August 1969 recording the site selection and completion of the two lighthouses, which were built and lit in 1972. Peru later argued that the commissions in question had been tasked only with erecting navigational aids for artisanal fishermen, not with demarcating or confirming any maritime frontier, and that the acts' references to a "maritime boundary" reflected imprecise drafting. Chile treated the acts as evidence that both countries recognized an existing maritime boundary along the parallel. Peru's lighthouse was damaged in an earthquake and dismantled in December 2001; the episode prompted a formal diplomatic protest from Chile after machinery entered Chilean-administered territory to remove debris.

The 1982 UN Convention on the Law of the Sea

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The Third United Nations Conference on the Law of the Sea produced the 1982 United Nations Convention on the Law of the Sea (UNCLOS), which set the territorial sea at 12 nautical miles and the exclusive economic zone at 200 nautical miles measured from baselines, and which specified that, absent historic rights or special circumstances, adjoining or opposite states should delimit their territorial seas along a median line equidistant from their respective baselines. Chile ratified UNCLOS in 1997, entering reservations under Article 298 that excluded it from the convention's compulsory dispute-settlement procedures for maritime boundary disputes — leaving the ICJ as the only forum with jurisdiction over such a dispute involving Chile. Peru signed UNCLOS in 2001 but, citing its constitutional claim to a 200-nautical-mile maritime domain, has not ratified it.

The 1986 Bákula memorandum

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Peru's Foreign Minister Allan Wagner first raised the question of a maritime boundary treaty with his Chilean counterpart, Jaime del Valle, in 1985. The following year, Peru's ambassador in Santiago, Juan Miguel Bákula Patiño, delivered a diplomatic note to del Valle, dated May 23, 1986, proposing formal negotiations to conclude "a treaty on maritime boundaries," on the premise that the delimitation of the two countries' maritime spaces remained formally undefined. Del Valle reportedly told Bákula in response that "the maritime boundary with Peru is a problem we have to study, and one we cannot put off indefinitely." Chile later argued before the Court that the exchange did not reflect an acknowledgment that no boundary existed, but rather Peru's own request to revise or clarify an already-settled line.

2004–2007 diplomatic exchanges

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On July 19, 2004, Peru's foreign minister, Manuel Rodríguez Cuadros, sent Chile's foreign minister, Soledad Alvear, a formal note proposing the opening of bilateral negotiations to fix the maritime boundary "through a specific treaty on the matter"; Chile's reply in September maintained that the 1952 and 1954 accords already constituted a boundary settlement. In November 2004, the two countries' foreign ministers issued a joint communiqué in Rio de Janeiro describing the disagreement over delimitation as "a matter of a legal nature" that was "strictly a bilateral issue" that should not interfere with the broader relationship between the two countries.

In 2005, Peru's Congress took up a bill to fix the baselines of the country's 200-nautical-mile maritime domain under Article 54 of the 1993 Constitution of Peru. The proposed baselines, running from the "Concordia Point," used the bisector method recommended under UNCLOS to divide the overlapping 200-mile zones with Chile in the south. The Peruvian Congress approved the bill unanimously (98–0) on November 3, 2005, and it was promulgated the same day as Law No. 28,621, the Law on the Baselines of Peru's Maritime Domain.

The bill's introduction, which had not previously been foreshadowed as a matter of urgency, provoked a sharp reaction in Chile, whose government, led by President Ricardo Lagos, rejected any Peruvian claim to waters south of the parallel through Boundary Marker No. 1; the National Congress of Chile approved a resolution backing the government's position. Peru's government called Chile's reaction disproportionate, and Bolivia and Ecuador — initially reluctant to become involved — eventually weighed in as well; on December 2, 2005, Chile and Ecuador signed an agreement reaffirming the validity of the 1952 and 1954 accords, which Peru's government criticized. In August 2007, following passage of the baselines law, Peru published new official charts depicting its 200-nautical-mile maritime domain, including the disputed trapezoid-shaped area and an adjoining "outer triangle" it labeled as an "area in controversy."[5]

Chile lodged a formal objection to Peru's baselines law with the United Nations' Division for Ocean Affairs and the Law of the Sea in May 2007, and Peru responded with its own note in August 2007 reasserting that the demarcation of 1930 fixed the land boundary's coastal terminus at the "Concordia Point," not at Hito No. 1. Separately, a provision of a 2006 Chilean law creating the new Arica y Parinacota Region, which described "the parallel of Boundary Marker No. 1 in the Chilean Sea" as the region's northern limit, drew formal protests from Peru's foreign ministry; Chile's Constitutional Court struck the provision in January 2007 on a procedural ground unrelated to the merits of the boundary question.

2011 Peru–Ecuador exchange of notes

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In May 2011, Peru and Ecuador exchanged identical diplomatic notes defining their shared maritime boundary in detail on the basis of "special circumstances in the area," without invoking the 1952 or 1954 accords; the exchange was jointly registered with the United Nations. Ecuador subsequently informed the Court that it would not seek to intervene in the pending Peru–Chile case. Peru argued that the 2011 exchange constituted the first and only agreement ever concluded on a Peruvian maritime boundary, reinforcing its position that the 1950s accords with Chile and Ecuador were fisheries-conservation measures rather than boundary treaties; Chile countered that Ecuador's own account of the 2011 exchange described it merely as ratifying an existing nautical chart based on the 1952 and 1954 agreements.

Positions of the parties

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Peru's position

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Peru argued that it and Chile had never concluded a treaty specifically delimiting their maritime boundary under modern principles of the law of the sea, and that the 1952 and 1954 instruments were fisheries-conservation measures adopted to address the depredations of foreign fishing fleets, not boundary agreements. It contended that the "Concordia Point," not the inland marker Hito No. 1, was the proper coastal terminus of the land boundary under the 1929 Treaty of Lima and the 1930 demarcation act, and that in the absence of an agreed boundary the Court should apply the equidistance method, drawing a boundary along a line bisecting the angle formed by perpendiculars to each country's coast, running in a southwesterly direction from the coast.[6] Peru further asked the Court to recognize Peru's exclusive sovereign rights over a maritime area, known as the "outer triangle," lying beyond 200 nautical miles of Chile's coast but within 200 nautical miles of Peru's, which Chile treated as high seas.

Chile's position

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Chile argued that the maritime boundary had already been fully and definitively settled by agreement, running along the parallel of latitude passing through Boundary Marker No. 1 (18° 21′ 00″ S), and that Peru had no entitlement to any maritime zone south of that parallel.[7] Chile pointed to the text of the 1952 Declaration of Santiago and the 1954 Special Maritime Frontier Zone Agreement, arguing that regardless of the conferences' broader stated purpose of conserving marine resources, both instruments' express references to "the maritime boundary" and to a "paralelo" presupposed an existing line and functioned in law as boundary agreements. Chile also relied on the 1968–1969 lighthouse arrangements and on decades of enforcement practice — including the interception, prosecution, and repatriation of Peruvian fishing vessels that crossed the parallel — as evidence that both states had long recognized and acted upon a boundary at that latitude.

Proceedings before the International Court of Justice

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Ambassador Alberto van Klaveren, Chile's agent before the Court
Ambassador Allan Wagner, Peru's agent before the Court

Application and written phase

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Peru instituted proceedings on January 16, 2008, by filing an application with the Registry of the Court, formally styled Case concerning the Maritime Delimitation between the Republic of Peru and the Republic of Chile. Both countries were parties to the 1948 American Treaty on Pacific Settlement (Pact of Bogotá), which the Court accepted as the basis of its jurisdiction. Peru's legal team included jurist Juan Vicente Ugarte del Pino;[8] its agent before the Court was Ambassador Allan Wagner. Chile's agent was Ambassador Alberto van Klaveren, a former Under-Secretary of Foreign Affairs.

Peru filed its memorial on March 19, 2009. Chile's government decided in June 2009 not to raise preliminary objections to the Court's jurisdiction, choosing instead to address both jurisdictional and merits questions in a single counter-memorial, filed March 9, 2010. On May 23, 2010, the Court notified Ecuador — as a party to the 1952 and 1954 instruments — of the proceedings and its right to seek to intervene; Ecuador subsequently indicated it would not do so, having separately published its own nautical chart in August 2010. Peru filed its reply on November 9, 2010, and Chile its rejoinder on July 11, 2011, closing the written phase.

Oral phase

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The Court held public hearings from December 3 to December 14, 2012, with each party presenting two rounds of oral argument.[9] Peru's delegation, led by agent Allan Wagner, opened the hearings on December 3 and 4; Chile's delegation, led by agent Alberto van Klaveren, presented on December 6 and 7. At the close of the first round, Judge Mohamed Bennouna asked both parties whether, as signatories to the 1952 Declaration of Santiago, they could at that date have lawfully proclaimed and delimited an exclusive maritime zone extending 200 nautical miles from their coasts under general international law then in force. In its reply on December 11, Peru argued that the three states could not have done so consistent with the international law of the time; in its rejoinder on December 14, Chile responded that the signatories were conscious of the novelty of their declaration, which it described as "the first manifesto" of a new political, economic, and environmental claim.

Judgment

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The maritime boundary between Chile and Peru as set by the International Court of Justice on January 27, 2014

The Court announced on December 13, 2013, that it would deliver its judgment on January 27, 2014.[10] On the appointed day, President Peter Tomka read a summary of the judgment before the full bench of sixteen judges at the Peace Palace, in the presence of the agents of both countries.[11]

Rather than adopting either party's proposed method wholesale, the Court examined the parties' practice since the 1940s and concluded that Peru and Chile had, through consistent conduct rather than an express treaty, tacitly agreed to an "all-purpose" maritime boundary running along the parallel of latitude through Boundary Marker No. 1, but that the evidence — principally the extent of 1950s fishing activity by small vessels operating within about 60 nautical miles of the coast — supported the existence of that agreed boundary only to a distance of 80 nautical miles from the coast, not all the way to the 200-mile limit as Chile contended.[12] Beyond that point (Point A), where no agreed boundary existed, the Court applied its standard three-stage equidistance/relevant-circumstances methodology to delimit the remaining, overlapping 200-nautical-mile entitlements of the two states, producing a line that runs southwest from Point A along the equidistance line to a point (Point B) on the 200-nautical-mile limit measured from Chile's baselines, and then follows that 200-mile limit south to a further point (Point C) on the 200-nautical-mile limit measured from the baselines of both states.[13]

By fifteen votes to one, the Court found that the starting point of the boundary was the intersection of the parallel through Boundary Marker No. 1 with the low-water line, and that the initial segment of the boundary followed that parallel; by ten votes to six, it found that this segment extended 80 nautical miles to Point A, and that from Point A the boundary continued southwest along the equidistance line to Point B and then along the 200-nautical-mile limit to Point C. By fifteen votes to one, it further found that, in light of this delimitation, it did not need to rule separately on Peru's claim to the "outer triangle," since that area fell within the maritime zone the new boundary allocated to Peru.[14] As is customary in maritime delimitation judgments, the Court described the course of the boundary without itself calculating precise geographic coordinates, leaving that task to the parties.

The judgment gave Peru sovereign rights over an area of ocean estimated at approximately 50,000 square kilometers, of which roughly 22,000 square kilometers had previously been treated by Chile as part of its exclusive economic zone and approximately 28,470 square kilometers had been treated by Chile as high seas; Chile retained sovereignty and sovereign rights over about 16,350 square kilometers of sea nearer its coast, encompassing the bulk of the area's most productive coastal fishing grounds, including some of the world's richest anchoveta fisheries.[15]

On March 25, 2014, representatives of the two governments signed an act in Lima fixing the precise geographic coordinates of the boundary in accordance with the judgment.[16]

Implementation and reactions

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The disputed area (left) and the boundary as set by the ICJ's 2014 ruling (right)

Both governments publicly pledged to comply with the judgment. Peruvian President Ollanta Humala described the ruling as a triumph achieved through peaceful, rules-based dispute resolution, while Chilean President Sebastián Piñera said his government would respect the decision and coordinate its implementation with President-elect Michelle Bachelet, who took office in March 2014, weeks after the ruling.[17] In the days after the ruling, Peruvian naval vessels sailed into the newly recognized waters, including the former "outer triangle," to carry out oceanographic and fishery-assessment surveys, formally asserting Peru's exercise of sovereign rights there.[18]

Commentators noted that the judgment represented a compromise that left both governments able to claim a measure of vindication: Peru secured a formal ruling that no boundary had ever been agreed beyond 80 nautical miles and gained a substantial expanse of ocean, while Chile retained the nearshore waters that hold the bulk of the disputed area's commercial fishing value, an industry estimated in press accounts at the time to be worth roughly $200 million a year.[19] Analysts also framed the case as part of a broader pattern of Latin American states submitting long-standing territorial and maritime disputes to international adjudication rather than resorting to force, a trend that continued shortly afterward with Bolivia's own application to the ICJ seeking to compel Chile to negotiate over Bolivian access to the Pacific.[20]

In Chile

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Following the judgment, Chilean politicians across several parties, including senators and deputies Iván Moreira,[21] Jorge Tarud, Jaime Orpis,[22] and Fulvio Rossi, criticized the ruling and called for Chile's withdrawal from the Pact of Bogotá, which would also mean abandoning the ICJ's compulsory jurisdiction over future disputes. Former President Ricardo Lagos also criticized aspects of the tribunal's reasoning.[23] Incoming foreign minister Heraldo Muñoz said the question of Chile's continued membership in the Pact of Bogotá was open to "legitimate discussion,"[24] and on February 11, 2014, President Piñera requested a formal report on the advantages and disadvantages of withdrawal.[25] Separately, some Chilean commentators criticized the Piñera government's broader diplomatic strategy of pursuing close commercial ties with Peru while the case was pending — described in the Chilean press as a policy of "separate tracks" (cuerdas separadas) — arguing it had weakened Chile's position; the policy's chief proponent was said to have been Foreign Minister Alfredo Moreno Charme.[26]

In Peru

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In Peru, the conduct of the case attracted little sustained criticism, and commentators broadly credited the country's foreign ministry for its handling of the litigation, which enjoyed the public support of President Humala and former presidents Alan García and Alejandro Toledo as a matter of continuing state policy across changes of government.[27] A notable exception was an open letter from writer Álvaro Vargas Llosa questioning the government's approach, which drew strong pushback from Peru's foreign ministry and widespread criticism in the Peruvian press.[28] Other Peruvian critics argued that the outcome fell short of a clear victory, noting that the southern region of Tacna did not gain the full 200-nautical-mile maritime zone Peru had sought, and that the waters Peru did receive constituted an exclusive economic zone rather than full territorial sovereignty.[29]

Significance

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Legal commentators described the judgment as noteworthy for finding that the parties had established a partial maritime boundary through consistent state practice — rather than through an express boundary treaty — while nonetheless limiting the reach of that tacit agreement to 80 nautical miles based on the extent of 1950s small-scale fishing activity that the 1954 agreement had been designed to regulate.[30] The case has since been cited as an example of the ICJ's willingness to find binding boundary agreements in historical conduct and technical arrangements — such as the lighthouse acts of 1968–1969 — even where the parties dispute the intent behind those arrangements.[31] More broadly, the peaceful resolution of a dispute rooted in the nineteenth-century War of the Pacific was cited by observers as evidence of a wider trend among Latin American states of turning to international adjudication, rather than unilateral action, to settle long-standing territorial and maritime disagreements.[32]

See also

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References

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  1. ↑ Corder, Mike (January 27, 2014). "World court draws new Peru-Chile maritime border". ap.org. Associated Press. Retrieved January 27, 2014.
  2. ↑ "Maritime Dispute (Peru v. Chile) — The Court determines the course of the single maritime boundary between Peru and Chile". International Court of Justice. January 27, 2014. Retrieved September 20, 2026.
  3. ↑ "Maritime Dispute (Peru v. Chile)". International Court of Justice. Retrieved September 20, 2026.
  4. ↑ "Tratado de Lima". Wikisource.
  5. ↑ "Carta del Límite Exterior– Sector Sur del dominio marítimo del Perú". Archived from the original on September 27, 2007. Retrieved August 14, 2007.
  6. ↑ "Memorial of the Government of Peru" (PDF). Archived from the original (PDF) on February 2, 2014.
  7. ↑ "Counter-Memorial of the Government of Chile" (PDF). Archived from the original (PDF) on February 2, 2014.
  8. ↑ "Murió Vicente Ugarte del Pino, miembro de equipo ante La Haya". El Comercio. October 6, 2014. Retrieved October 25, 2015.
  9. ↑ "The Court to hold public hearings from Monday 3 to Friday 14 December 2012" (PDF). Archived from the original (PDF) on January 1, 2014.
  10. ↑ "The Court to deliver its Judgment on Monday 27 January 2014 at 3 p.m." (PDF). Archived from the original (PDF) on February 2, 2014.
  11. ↑ "Summary of the Judgment of 27 January 2014". International Court of Justice. January 27, 2014. Retrieved September 20, 2026.
  12. ↑ "ICJ delimits Peru-Chile maritime boundary". Herbert Smith Freehills. Retrieved September 20, 2026.
  13. ↑ "International Court of Justice Defines Maritime Boundary Between Peru and Chile". American Society of International Law. February 10, 2014. Retrieved September 20, 2026.
  14. ↑ "Maritime Dispute (Peru v. Chile), Judgment" (PDF). Archived from the original (PDF) on February 10, 2015.
  15. ↑ "Court grants Peru ocean territory claimed by Chile". GeoGarage blog. January 28, 2014. Retrieved September 20, 2026.
  16. ↑ "Coordenadas del límite marítimo con Chile se definieron en actas". El Comercio. Retrieved March 26, 2014.
  17. ↑ "Piñera ratifica que Chile acatará fallo y anuncia coordinación con Bachelet para su implementación". La Tercera. January 27, 2014. Archived from the original on January 28, 2014.
  18. ↑ "Naves peruanas navegan en mar reconocido como peruano". El Comercio. Retrieved February 3, 2014.
  19. ↑ "Court grants Peru ocean territory claimed by Chile". GeoGarage blog. January 28, 2014. Retrieved September 20, 2026.
  20. ↑ "The Maritime Dispute Between Peru and Chile". E-International Relations. March 21, 2014. Retrieved September 20, 2026.
  21. ↑ "Fuertes críticas de parlamentarios: "Aquí Chile no ha ganado nada, hemos perdido"". La Segunda. January 27, 2014.
  22. ↑ "Full". La Estrella de Arica. January 27, 2014. Archived from the original on February 2, 2014.
  23. ↑ "Ex-presidente Lagos: "No entiendo por qué el paralelo es hasta las 80 millas y después se quiebra"". La Segunda. January 28, 2014.
  24. ↑ "Muñoz se abre a debatir retiro de Chile de Pacto de Bogotá: "Es una discusión legítima"". La Segunda. January 28, 2014.
  25. ↑ "Presidente pidió informe de pros y contras ante retiro de Pacto de Bogotá". La Segunda. February 11, 2014.
  26. ↑ "La Haya y el fracaso de la tesis de las cuerdas separadas con Perú". El Mostrador. November 28, 2012.
  27. ↑ "Agente de Perú no se refiere a decisión de la CIJ". América Economía. January 27, 2014. Retrieved February 22, 2014.
  28. ↑ Vargas Llosa, Álvaro (December 15, 2012). "Carta abierta a Torre Tagle". La Tercera. Archived from the original on December 15, 2012.
  29. ↑ "Roberto Chiabra sobre fallo de La Haya: "Ganó Perú pero perdió Tacna"". Capital. January 28, 2014. Retrieved February 22, 2014.
  30. ↑ "ICJ delimits Peru-Chile maritime boundary". Herbert Smith Freehills. Retrieved September 20, 2026.
  31. ↑ "International Court of Justice Defines Maritime Boundary Between Peru and Chile". American Society of International Law. February 10, 2014. Retrieved September 20, 2026.
  32. ↑ Paterson, Patrick J. (March 5, 2015). "The Peru-Chile Maritime Dispute: A Case Study". Retrieved September 20, 2026.
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