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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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  • In France, rather than one specific significant change, it's been more a question of continuous embedding of Base Erosion and Profit Shifting (BEPS)-influenced changes in the French domestic legislation. Both the European Union and Organisation for Economic Co-operation and Development (OECD) have had more impact on the French tax features, leading to more transparency (e.g. through Country-by-Country Reporting (CbCR) and the recent Mandatory Disclosure Rules) and to more restrictions in terms of financing deductions.
  • 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.
  • Herminia Diaz

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