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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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  • Anne Becker-Christensen
  • In France, rather than one specific significant change, it's been more a question of continuous embedding of Base Erosion and Profit Shifting (BEPS)-influenced changes in the French domestic legislation. Both the European Union and Organisation for Economic Co-operation and Development (OECD) have had more impact on the French tax features, leading to more transparency (e.g. through Country-by-Country Reporting (CbCR) and the recent Mandatory Disclosure Rules) and to more restrictions in terms of financing deductions.
  • Mariana Jatahy Rizzo Soares

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