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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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  • Alejandro Paredes of Deloitte provides an insight into the methods and characteristics of the Chilean tax authority’s transfer pricing (TP) team, and highlights how the training, expertise and professional outlook of the team has resulted in a focused, successful and understanding TP unit that is willing to liaise with taxpayers and tax advisors to achieve a positive outcome for all.
  • The Brazilian presidential election in 2018 may substantially affect the transfer pricing (TP) analysis of local taxpayers and increase eventual adjustments on import transactions, as a consequence of an unfavourable exchange rate variation, writes Daniel Macedo of Deloitte.
  • The OECD BEPS project has quickly moved to the implementation phase, leaving an essentially changed landscape in its wake, write Deloitte practitioners from the Latin America Countries Organisation. This new environment requires businesses to reconsider their operational, financing and holding structures, identify communications strategies and assess their tax strategy, all with the aim of developing a maintainable tax framework.

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