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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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  • Margaret Hodge, UK MP for Barking, who chairs the All Parliamentary Party Group (APPG) on Responsible Tax, speaks to International Tax Review about the Paradise Papers and how best to tackle tax avoidance in a modern global economy.
  • Peter Nias, barrister and Centre of Effective Dispute Resolution (CEDR) panel mediator of Pump Court Tax Chambers in the UK, considers whether the arbitration provisions in the OECD’s Multilateral Instrument (MLI) and Action 14 proposals offer the only option for dispute resolution for all parties.
  • A suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.

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