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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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  • For the past couple of years, many commentators have used the term “disruption,” sometimes without much forethought, writes Carolyn Bailey, Americas digital tax administration services leader at EY. It sells newspapers, magazines and journals, and it attracts television viewers.
  • Read this month's special features on Tax technology and transformation and Mexico
  • The concept of having an optimal equity structure, including debt instruments, is being slowly shredded by tax perceptions and legislation, imposing additional cash costs for this historic and sound economic position, writes Keith Brockman.

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