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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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  • In the third of a series on intangibles, Philip de Homont and Alexander Voegele, both of NERA Frankfurt, look at brand management centres in the age of BEPS.
  • The envisaged ideals of ‘tax transparency’ are being proposed, and legislated, by tax administrations worldwide. This month’s Brockman brief focuses on the fact that mutual and reciprocal tax transparency with multinational entities (MNEs) remains somewhat elusive. It is now time to briefly assess some of these initiatives to fairly gauge the mutuality of such initiatives.
  • To start his new monthly column, Ralph Cunningham, the Hong Kong-based managing editor of International Tax Review, argues that capacity building will be critical to BEPS implementation in the Asia-Pacific region if piecemeal, unilateral measures are to be avoided.

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