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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 conjunction with International Tax Review, Deloitte Touche Tohmatsu is pleased to present the 2019 Transfer Pricing Energy and Resources guide, a collection of industry thought papers produced by Deloitte member firm transfer pricing (TP) professionals in the energy and resources (E&R) industry.
  • In-house tax teams are implementing tailored software solutions due to the low cost of technology, but should beware of ‘over-tooling’ and employ a coherent purchasing strategy, writes Danish Mehboob.
  • A well-constructed and executed global operational transfer pricing (OTP) framework is essential to properly manage financial statements, taxes and reputational risk for multinational enterprises (MNEs), writes Richard Goldberg, former tax director at Mitsubishi Financial Group.

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