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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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  • Jasper Korving and Loes van Hulten of Deloitte provide an overview of the MLI, focusing in particular on the principal purpose test (PPT), an anti-treaty abuse measure in the convention, how the PPT might apply in practice, and its potential impact on companies.
  • The taxpayer challenges arising from the EU’s directive on mandatory disclosures for intermediaries (DAC 6) are seemingly countless, writes Christian Kaeser, global head of taxes at Siemens, and Mark Orlic and Arne Schnitger of PwC.
  • Drawing on China and international experience with the digitalisation of taxation, in particular as it relates to indirect taxation, Lachlan Wolfers, Vincent Pang, John Wang and Grace Luo chart out the possible future of tax rules, tax administration, and the tax profession itself.

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