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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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  • In the hype of the BEPS Project, Mexico has been one of the most active countries in applying the concepts of substance, transparency and consistency, write Simón Somohano and David Cárdenas of Deloitte.
  • The 2014 Tax Reform Act and the 2016 Tax Reform Amendment Act gave the Chilean tax regulator new tools to contact taxpayers, request information, initiate examination processes and potential tax audits, and even to declare the termination of activities for certain businesses, write Roberto Carlos Rivas and Josefina Casals of PwC Chile.
  • Around 20 years ago the Brazilian Government, in order to deter tax evasion in the country, introduced rules aimed at avoiding the undue transfer of profits through transactions conducted between multinational companies and their parents or associates abroad, writes Carlos Ayub of Deloitte Brazil. Since then, all movements of goods, services, and rights between entities in the same group have been subject to transfer pricing rules.

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