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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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  • BEPS Action 5 – Countering harmful tax practices more effectively by taking into account transparency and substance is one of the four BEPS minimum standards. To date, 102 jurisdictions have committed to its implementation, and 2017 is a decisive year in translating that commitment into action. Achim Pross, Kevin Shoom and Melissa Dejong of the OECD, discuss the first results of the work under BEPS Action 5, and its significance in achieving the goals of the BEPS project.
  • With the CCCTB back on the EU agenda, Richard Murphy, professor of practice in international political economy at City, University of London, argues it does not represent true consolidation and could fail in its objectives.
  • The OECD has continued to evaluate and work on refining its transfer pricing guidelines regarding several BEPS initiatives, write David Jarczyk and John Wiora of ktMINE.

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