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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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  • Over the past year, the Australian transfer pricing (TP) landscape has continued to evolve. There is new legislation and the Australian Taxation Office (ATO) is continuing to prioritise TP as a key area, write Tim Keeling, Jay Mankad and Jennifer Goldkopf of KPMG.
  • Indonesia completed the last step in the introduction of new transfer pricing regulations late last year, report Iwan Hoo, Aaron Brunier and Fachrur Rifqi Nugroho of KPMG. While the regulations covering the master file, local file and country-by-country reporting were issued in 2016, the implementing regulations for CbCR were not completed until late December 2017.
  • The National Assembly of Korea approved the 2017 Tax Reform Bill on December 5 2017, write Gil Won Kang, Sang Hoon Kim and Seung-Mok Baek of KPMG.

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