There are clear and often long deadlines within which the WFP can be requested. In particular, the second sentence of Article 16(1) of the MLI provides that the POPs case must not be brought within a certain period, that is to say, less than three years from the first filing of the tax action, in accordance with the provisions of a tax treaty concerned. This means that taxable persons may not bring their case within three years of the first notification of the action giving rise to the taxation in accordance with the provisions of the tax treaty concerned. The first notification is generally considered to be the final assessment at the end of a tax or similar application. Legal restrictions on compulsory arbitration are still ongoing and depend on the judicial system of the state and territory of the country where the agreement is being tested. It is important that it provides for a mandatory and binding arbitration mechanism that eliminates double taxation by referring to the opinion of an independent advisory body if the competent authorities do not reach an agreement after two years. .