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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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  • Read this month's special features on tax technology and transformation, Mexico and New Zealand
  • Former managing director of State Street Bank and leading financial expert Avinash Persaud tells Salman Shaheen why he has designed a financial transaction tax (FTT) for Britain’s opposition Labour Party to help rein in the City of London.
  • The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

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