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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 four founders of TaxCOOP, Brigitte Alepin, Allison Christians, Lyne Latulippe, and Louise Otis introduce their forum for developing good tax policy.
  • 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.
  • The tax regimes governing the gig economy, combined with the rules on self-employed individuals, have led to the success of companies such as Uber and Deliveroo. However, the Taylor Review on modern working practices has suggested radical changes that could change it all and stop other sectors adopting similar practices. Anjana Haines talks to the report’s author, Matthew Taylor, to discuss his recommendations and what they could mean for the future of the gig economy.

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