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Direct Tax
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
February 3, 2026
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  • The tax changes that Congress passed and President Trump signed into law in December 2017 are the most significant overhaul of the US Tax Code in three decades. These changes lowered the tax rates on corporations, pass-through entities, individuals and estates and moved the United States towards a participation exemption-style system for taxing the foreign-sourced income of domestic multinational corporations. To help offset the revenue impact of these changes, the new law also scaled back or eliminated longstanding deductions, credits and incentives for businesses and individuals.
  • Benedicta Du-Baladad
  • The Finance Act 2017 was diverse, from introducing targeted anti-avoidance legislation, to changes to the taxation of certain funds and securitisation companies, as well as introducing a sugar tax.

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