Even in the event of an arbitration request, the EU review found that there could be many shortcomings in the system, including delays or lack of setting up the advisory committee and the lack of agreement on the appointment of the chairman of the advisory committee that delays or prevents the procedure. Deloitte Peru works with clients to develop an integrated and comprehensive local strategy that is effective in addressing the many complex issues associated with the cross-border transfer of intangible goods, services and goods. Deloitte Peru`s TP team has a good reputation for quality and results. Services include transfer pricing planning and documentation, dispute prevention, including advance Pricing Agreements with local tax authorities, dispute resolution, including audit defence and mutual agreement/competent authority procedures, and business model optimization (BMO). Overall, it is clear that the MLI extends taxpayers` access to three years, both in terms of extending the period during which taxpayers must initiate a POB period, provides an effective two-year period for the relevant authorities to resolve a case (after that date, it may be subject to arbitration). The MLI has led to a greater homogeneity of approach on key issues such as arbitration and, above all, the adoption of a single map article for covered tax treaties. Eric has more than 15 years of experience in transfer pricing and international taxes. Since 1998, Eric Lesprit has worked for the French tax administration on international corporate and personal tax issues. It was there that he participated in the development of the pre-award agreement programme in France in 1999, before leading it. From 2003 to 2006, he was the IMF`s technical advisor in Washington D.C. for government revenue (taxes and customs duties).

Since 2013, he has also been responsible for reciprocal agreement procedures aimed at abolishing double taxation. As part of his missions, he was the French administration`s representative for the procedures of the competent authorities abroad, particularly with regard to transfer pricing. He has been involved for several years in the work of the OECD and the EU. He was involved in the development of legislation on anti-fraud and tax control policy, as well as in the management of the exchange of tax information and in the management of the French audit network directorates. At the international level, he interfered in the definition of French positions at the working meetings of the European Community and the OECD, in particular with regard to the fight against tax havens and the negotiation of the exchange of tax information with non-cooperative territories. In 2015, Eric joined Taj`s transfer pricing department. It helps to prevent risks related to international taxation in general and transfer pricing in particular. The POPs guidelines provide that subjects applying for POPs must provide gazT with transfer pricing documentation in addition to the information necessary to justify the case.