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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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  • Andre Schaffers and Filip Vanluydt of Deloitte explain the concept of embedded intellectual property (IP), providing detailed guidelines for readers on how to identify and quantify it.
  • The German approach to determining the arm’s-length price for intangibles/intellectual property (IP) is based on the relevant German tax code and related administrative guidance, explain Richard Schmidtke, Bjorn Heidecke and Oskar Glaser of Deloitte. If other methods are used to determine the arm’s-length price for IP, this may result in non-compliance in Germany.
  • Brands are complex intangible assets. As explained by Tim Heberden and Cam Smith of Deloitte, robust valuations and royalty opinions should incorporate analysis of the legal rights underpinning the brand, together with the associated reputational stock that drives purchase behaviour.

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