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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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  • David Forst and Jim Fuller of Fenwick & West summarise numerous developments in the US M&A tax landscape after a record year for dealmaking – driven by healthcare and technology industries – which puts 2015 on par with 2007 numbers, adjusted for inflation.
  • Michael Lebovitz and Stephen Weerts of White & Case unpick how the recommendations from the OECD BEPS Action Plan, and EU state aid investigations, are likely to change the world of M&A.
  • The 2015 enhancements to China’s restructuring tax relief rules, the challenging new indirect offshore disposal rules in SAT Announcement 7, developments in financial instrument tax classification and the revamped tax treaty relief procedures are the focus of this article by KPMG’s John Gu, State Shi, Josephine Jiang, Chris Mak and Yvette Chan.

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