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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 Budget season is about to start in Asia. Ralph Cunningham believes finance ministers are likely to prioritise local or regional concerns rather than get involved in any deep discussions about base erosion and profit shifting.
  • Carrie Aiken and Dan Jankovic of Blake, Cassels & Graydon unpick the new Canadian payroll withholding tax exemption, analysing how qualifying taxpayers can benefit and providing tips for continued compliance.
  • Mexico is one of the few countries with a special exemption regime for foreign pension funds investing in the country. This exemption was incorporated into the tax system as a general withholding exemption for such funds when obtaining any type of Mexican source income through a presidential decree published on March 25 1992, and then into the Income Tax Law in July of that year. Raul Morales Medrano of Chevez, Ruiz, Zamarripa y Cía, outlines the latest changes impacting pension funds in Mexico.

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