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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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  • Following the agreement of the European Council on the Anti-Tax Avoidance Directive (ATAD) on July 12 2016, EU member states now are required to implement certain anti-tax avoidance provisions into their domestic laws by December 31 2018 and have them apply as from January 1 2019 (except for the exit tax rules), write Alexander Linn and Thorsten Braun of Deloitte.
  • Amendments to Mexico’s VAT Law will significantly increase the costs for business taxpayers. Cesar De la Parra and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cia explain the changes.
  • Maik Heggmair and Tobias Faltlhauser of WTS summarise the new transfer pricing (TP) documentation rules to be implemented in Germany and provide an example of new TP risk assessment possibilities based on new country-by-country reporting (CbCR), which may become relevant for MNEs in the near future.

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