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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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Many years ago, I was responsible for a tax group that reported to a regional group services organisation and not to the global head of tax. A new manager, with no experience of tax, had just taken over responsibility for group services and was looking to find out what each of his new teams actually did and for simple performance metrics. -
Keith Brockman looks at how to prevent and resolve disputes just as the international tax system is changing.
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Opportunities to come to a resolution with the tax authorities are generally better the earlier they present themselves in the life-cycle of a tax dispute, says Sandy Markwick, head of the Tax Director Network (TDN) at Winmark.
Sponsored Features
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
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Sponsored by DeloitteInterview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Spanish VAT ServicesThe ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps
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Sponsored by KPMG SwedenNils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation
