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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 most significant change is the sheer volume of it. I've been an international tax adviser to large multinational companies for over 30 years and never seen anything like the pace of change we are experiencing now. In the last 12 months we have had the Anti-Tax Avoidance Directive (ATAD), Multinational Instrument (MLI), US tax reform and the taxation of the digital economy, to name but a few of the changes to the international tax framework. All of these have a cascade and multiplying effect into domestic legislation. -
Sonia Louzir
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Weina Ang
Sponsored Features
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
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Sponsored by DeloitteInterview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Spanish VAT ServicesThe ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps
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Sponsored by KPMG SwedenNils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation
