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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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  • Judging by the speeches at the World Economic Forum in Davos, political and business leaders are concerned by the changing dynamics of international tax competition and there can be no doubt that the ‘race to the bottom’ is on.
  • With the avalanche and uncertainty of unilateral adoption of BEPS-related provisions by many countries, in addition to subjective general anti-abuse treaty-based legislation, excessive lead times and inefficiencies of competent authority/treaty approval processes are becoming more costly and significant for both taxpayers and tax administrations.
  • Margaret Hodge, UK MP for Barking, who chairs the All Parliamentary Party Group (APPG) on Responsible Tax, speaks to International Tax Review about the Paradise Papers and how best to tackle tax avoidance in a modern global economy.

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