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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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  • The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?
  • Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.
  • Gertjan Verachtert, attorney at Sansen International Tax Lawyers and member of AIJA, analyses Belgium’s new voluntary disclosure legislation in light of recent developments in information exchange, including the ‘Panama Papers’ leak.

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