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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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  • Lari Hintsanen
  • Véronique De Brabanter
  • The BEPS Project, new risk assessment tools, CbCR requirements, and enhanced enforcement actions, among other challenges, are creating unprecedented levels of uncertainty for taxpayers, writes C David Swenson, global leader of PwC’s tax controversy and dispute resolution network.

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