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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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  • Danaher Corporation’s Jim Ditkoff talks to International Tax Review about what the end of the inversion era means for US businesses.
  • A key role of heads of tax in large organisations is to be the ‘ambassador’ for tax, raising its profile and providing advice around opportunities and risks, writes Sandy Markwick, head of the Tax Director Network at Winmark. Being effective in this capacity requires advanced communications skills.
  • Gautier Ciresa, transfer pricing manager at Technicolor, explains why employees are the true indicator of value creation within MNEs and how to determine their impact in a transfer pricing analysis.

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