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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 rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.
  • Singapore has been increasing its focus on transfer pricing, explain Geoffrey K Soh, Felicia Chia and Jingyi Lee of KPMG, with yearly revisions of the TP guidelines as well as the adoption of country-by-country reporting requirements. Recently, there has been a greater-than-ever push to ensure that taxpayers’ profitability is consistent with the economic activities conducted and value generated.
  • In recent years, the number of enquiries received by the Chilean tax authority regarding the impact in Chile from international and cross-border reorganisations has grown exponentially, write Santiago López and Stephanie Chacra of PwC Chile. Indeed, in past international updates we have reported how the Chilean IRS has been formulating uniform criteria for this purpose.

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