BEPS
KPMG TaxNewsFlash reports about OECD's base erosion and profit shifting (BEPS) initiative and tax transparency
News
Cameroon: Guidelines for local country-by-country declarations
Content, format, and procedures for filing local CbC declarations
March 6, 2025
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Indonesia: Implementation of global minimum tax
Enforcement of global anti-base erosion (GloBE) rules from January 1, 2025
March 5, 2025
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OECD: BEPS Action 14 MAP peer review results
Progress in making dispute resolution more effective under the BEPS package
March 5, 2025
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UAE: FAQs on Pillar Two domestic minimum top-up tax
Ministry of Finance published a list of “frequently asked questions”
March 4, 2025
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Latest tax developments from the United States and from KPMG member firms around the globe
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Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
Recent tax developments in Germany
January 30, 2025
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Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
January 29, 2025
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Bahrain: Updated domestic minimum top-up tax registration manual
Updated version of domestic minimum top-up tax registration manual released
January 27, 2025
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France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
January 27, 2025
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Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
Rules are effective from January 1, 2024.
January 22, 2025
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South Africa: Legislation implementing Pillar Two global minimum tax rules enacted
Rules are effective for tax years beginning from January 1, 2024
January 22, 2025
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White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
January 21, 2025
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Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting
Implementing laws largely align with EU directives
January 21, 2025
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Bahrain: Guide on entities within scope of domestic minimum top-up tax
Further clarification on various aspects including entities that fall within scope of domestic minimum top-up tax
January 21, 2025
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EU: Tax priorities of Polish Presidency of the Council
Include updating list of non-cooperative jurisdictions for tax purposes and work on DAC9
January 21, 2025
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Thailand: Law implementing Pillar Two global minimum tax rules published
Rules became effective January 1, 2025
January 21, 2025
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KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
January 17, 2025
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KPMG report: Inclusive Framework Administrative Guidance on limitation of the use of deferred tax assets under transitional rules (Article 9.1)
Focuses on the guidance on deferred tax assets under Article 9.1
January 17, 2025
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OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration
Additional administrative guidance under the Pillar Two rules
January 15, 2025
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Spain: Law implementing Pillar Two global minimum tax approved
Law also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
January 15, 2025
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Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One
The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.
January 13, 2025
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Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities
Reports discussing key considerations for fund vehicles and Irish securitization entities
January 9, 2025
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North Macedonia: Parliament adopts law implementing Pillar Two global minimum tax rules
Law aligns with EU minimum tax directive
January 9, 2025
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Poland: Updated list of countries and territories applying harmful tax competition
Updated list became effective January 1, 2025
January 9, 2025
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Oman: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
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Kuwait: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
January 8, 2025
Highlighted Insights
BEPS 2.0: Pillar Two
KPMG insights about the impact of the Pillar Two—global minimum tax rules—and how companies are responding
Read more
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Australia: Legislation implementing Pillar Two global minimum tax rules passes Senate
Two bills will return to the House of Representatives, while the other awaits Royal Assent
November 27, 2024
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Hungary: Draft declaration form for taxpayers subject to global minimum tax
Form includes some changes from autumn tax package proposal
November 27, 2024
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Hungary: Amended autumn tax package submitted to Parliament
Tax changes expected to come into effect in Hungary
November 22, 2024
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Poland: Legislation implementing global minimum tax effective January 1, 2025
The new regulations target groups with annual revenues of €750 million or more.
November 21, 2024
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UK: Amendments to Pillar Two rules in Finance Bill 2024-2025
Seeks to incorporate the undertaxed profits rule (UTPR) into UK domestic law
November 21, 2024
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Singapore: Bills to implement global minimum tax; list of jurisdictions for exchange of CbC reports; applying for certificates of residence
Parliament passed bills to implement the multinational enterprise top-up tax and the domestic top-up tax
November 20, 2024
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South Africa: Updated legislation implementing Pillar Two global minimum tax rules submitted to Parliament
The government submitted legislation to implement the OECD’s Pillar Two GloBE model rules.
November 20, 2024
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OECD: Mutual agreement procedure (MAP) and advance pricing agreement (APA) statistics for 2023
Decrease in global MAP inventories with more cases resolved and an increase in global APA inventories
November 18, 2024
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Poland: Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament
The legislation is expected to become effective January 1, 2025.
November 13, 2024
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Bahamas: Proposed Pillar Two legislation
Minimum effective tax rate of 15% for MNE groups with global revenues exceeding €750 million
November 12, 2024
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Luxembourg: Revised draft law amending Pillar Two law
Revised draft law introduces additional amendments to initial amending draft law published in June 2024
November 8, 2024
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Hungary: Reporting obligation of taxpayers subject to global minimum tax
Taxpayers subject to global minimum tax must fulfill reporting obligation by December 31, 2024.
November 7, 2024
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Portugal: Bill implementing Pillar Two passed by Parliament
Parliament passed a bill transposing the EU minimum tax directive into domestic legislation
November 4, 2024
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Norway: Budget would introduce undertaxed profits rule (UTPR) from 2025
A proposal to introduce an undertaxed profits rule from 2025
November 4, 2024
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Italy: Guidance on substance based income exclusion (SBIE) provisions under Pillar Two rules
The decree incorporates clarifications provided in the OECD commentary and December 2023 administrative guidance.
November 4, 2024
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Hong Kong: Outcomes from Pillar Two consultation
Key points contained in the government’s responses
November 4, 2024
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Netherlands: Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives
Effect expected to be limited
November 4, 2024
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Latvia: Updated list of low-tax or tax-free jurisdictions
Updated list applicable from November 1, 2024
November 4, 2024
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Poland: Proposed reforms to tax incentives system in light of Pillar Two
Government is considering introduction of cash grant regime in lieu of existing investment zone and R&D tax credit regimes
November 4, 2024
Highlighted Insights
Global Transfer Pricing Review
Comprehensive information covering more than 100 countries and feedback on more than 200 questions covering local transfer pricing rules and regulations
Read more
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Germany: Annual Tax Act 2024 passed by lower house of Parliament includes Pillar Two changes, other tax developments
Recent tax developments in Germany
October 31, 2024
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UK: Pillar Two tax measures in Autumn Budget 2024
Undertaxed profits rule (UTPR) will be included in the Finance Bill 2024-2025
October 31, 2024
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EU: Proposal for exchange of Pillar Two global minimum tax information between EU member states (DAC9)
DAC9 proposal would transpose the global anti-base erosion (GloBE) information return (GIR) into EU law.
October 30, 2024
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Germany: Registering Pillar Two minimum tax group leader
Ministry of Finance has published a notification form for registering the minimum tax group leader.
October 30, 2024
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Hungary: Autumn tax package includes proposed Pillar Two amendments
Tax changes expected to come into effect in Hungary
October 29, 2024
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Malta: 2025 budget includes update on Pillar Two implementation
Highlights of Budget 2025
October 29, 2024
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New Zealand: Summary of implementation of Pillar Two GloBE rules
Rules effective for fiscal years starting on or after January 1, 2025
October 29, 2024
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Isle of Man: Update on implementation of Pillar Two global minimum tax
The new rules would take effect for accounting periods beginning on or after January 1, 2025.
October 28, 2024
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Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024
Proof of appointment must also be uploaded in FinanzOnline
October 24, 2024
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OECD: Developments in international tax reform—digitalization of the economy and BEPS minimum standards
Recent developments in international tax reform since July 2024
October 24, 2024
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Belgium: Public consultation on draft tax return under Pillar Two rules
Comments are due November 8, 2024.
October 21, 2024
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OECD: BEPS Actions 5 and 14 peer reviews
Second round of BEPS Action 5 peer reviews, first two batches of BEPS Action 14 peer reviews under simplified review process
October 16, 2024
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Bulgaria: Public consultation on proposed amendments to Pillar Two rules
The consultation runs until October 18, 2024.
October 16, 2024
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Netherlands: 2025 Tax Plan includes proposed amendments to Pillar Two rules
Most of the proposed amendments would have retroactive effect as of December 31, 2023.
October 16, 2024
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Slovakia: Draft legislation amending Pillar Two rules submitted to Parliament
The proposed amendments would become effective as of December 31, 2024.
October 16, 2024
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Lithuania: Public consultation on draft legislation fully implementing Pillar Two rules
The proposed Pillar Two rules would closely follow the text of the EU minimum tax directive.
October 16, 2024
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Italy: Public country-by-country reporting implemented
The new provisions apply to financial years beginning on or after June 22, 2024.
October 16, 2024
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Australia: Guidance on compliance approach to restructuring transactions in response to new thin capitalization rules
The draft guidance describes a series of low-risk and high-risk factors and a four-color-coded risk-assessment framework.
October 15, 2024
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France: Finance Bill 2025 includes proposed retroactive tax increases for large corporations and individuals, updates to Pillar Two rules
The Finance Bill for 2025 was published on October 10, 2024.
October 15, 2024
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Ireland: Tax measures in Finance Bill 2024, including Pillar One Amount B rules, amendments to Pillar Two rules
Includes tax measures announced in 2025 budget
October 11, 2024
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UK: Initial analysis of OECD’s model competent authority agreement on application of Amount B under Pillar One
MCAA can be used to apply Amount B when there is a tax treaty in place between two jurisdictions
October 10, 2024
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EU: Updated list of non-cooperative tax jurisdictions
EU blacklist now consists of 11 jurisdictions
October 9, 2024
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Netherlands: Interest deduction limitation anti-profit shifting rule permissible under EU law (CJEU judgment)
Rule is justified as a means of combating tax fraud and evasion
October 8, 2024
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KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America
PPT provisions make testing availability of treaty benefits for holding companies more complex
October 8, 2024
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Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax
Officially aligns Brazil with countries that have adopted the OECD's global anti-base erosion (GloBE) rules
October 7, 2024
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New Zealand: Updated compliance focus guide for multinationals reflects BEPS, Pillar Two changes
Guidance for multinationals in self-assessing their international tax and transfer pricing risk profiles
October 7, 2024
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OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
October 7, 2024
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Poland: Draft legislation implementing Pillar Two global minimum tax rules submitted to lower house of Parliament
The legislation is expected to become effective January 1, 2025.
October 2, 2024
Tax Services
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UK: Consultation on additional draft guidance on Pillar Two global minimum tax rules
Comments are due by October 23, 2024.
September 26, 2024
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KPMG report: U.S. transfer pricing and international tax year-end considerations
A report that includes key year-end transfer pricing and international tax issues.
September 25, 2024
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Australia: Increased reporting requirements for Local file
Proposed Local file and Master file XML schema 4.0
September 20, 2024
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OECD: Jurisdictions sign multilateral convention implementing Pillar Two subject to tax rule
Nine jurisdictions signed the multilateral convention to implement the STTR in bilateral income tax treaties.
September 19, 2024
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KPMG comments on European Commission consultation on ATAD
Evaluation of the Anti-Tax Avoidance Directive
September 19, 2024
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UK: European Commission’s finding of unlawful State aid annulled, judgment of General Court set aside (CJEU judgment)
The CJEU found that the EC and the General Court erred in law.
September 19, 2024
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Czech Republic: Proposed amendment to legislation introducing top-up tax, implementing EU directive on global minimum tax
A draft amendment to the law introducing a top-up tax to implement the EU directive on global minimum tax in the Czech Republic
August 27, 2024
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Germany: Proposed investment tax incentives, Pillar Two changes, intra-group financing transfer pricing guidance, MLI law enacted
Recent tax developments in Germany
August 27, 2024
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KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on India and South Korea
How tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks
August 26, 2024
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Australia: Proposed amendments to legislation implementing Pillar Two global minimum tax rules
The federal government proposed amendments to legislation implementing Pillar Two global minimum tax rules currently before parliament.
August 23, 2024
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Australia: Legislation implementing Pillar Two global minimum tax rules passes House of Representatives
The bills now move to the Senate for consideration.
August 22, 2024
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KPMG report: Potential effects on businesses of new UN tax treaty
A KPMG report that reviews the UN’s efforts to create a new tax treaty and explains why businesses need to monitor the UN process
August 21, 2024
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Poland: Domestic rules implementing DAC6 unconstitutional to extent tax advisors obliged to violate professional secrecy
A Constitutional Tribunal decision concerning domestic rules implementing DAC6 unconstitutional.
July 31, 2024
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Belgium: Mandatory disclosure rules (DAC6) compatible with EU law (CJEU judgment)
CJEU confirmed validity of mandatory automatic exchange of information for cross-border arrangements
July 31, 2024
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Australia: Updated thin capitalisation web guidance
The ATO updated its thin capitalisation web guidance to assist entities that need to apply the new thin capitalisation rules.
July 31, 2024
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Austria: Public country-by-country reporting implemented, draft amendments to transfer pricing guidelines
The law applies to financial years beginning after June 21, 2024.
July 30, 2024
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Tax report to G20 Finance Ministers and Central Bank Governors; other reports on international tax reform developments
The report describes key developments in international tax reform since February 2024.
July 25, 2024
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UN: Revised draft terms of reference for UN framework convention on international tax cooperation
A revised draft of terms of reference for a United Nations framework convention on international tax cooperation.
July 25, 2024
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OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
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Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One nearing completion
The OECD released a statement by the co-chairs of the Inclusive Framework on Base Erosion and Profit Shifting.
May 30, 2024
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Japan: Explanation of guidance on income inclusion rule, associated forms and schedules
National Tax Agency explanation of guidance relating to the income inclusion rule
May 30, 2024
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Belgium: Due date for first GloBE registration is July 13, 2024
July 13 is the due date for the first notification deadline for GloBE registration in Belgium
May 29, 2024
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Germany: Law implementing MLI passed by lower house of Parliament, other tax developments
The lower house of Parliament passed the "Law on the Application of the Multilateral Convention of 24 November 2016 and Further Measures."
May 28, 2024
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Crown Dependencies: Details on plans to implement Pillar Two global minimum tax
All islands have expressed intention to work cooperatively, but each is adopting a different approach.
May 24, 2024
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Slovakia: Guidelines on transfer pricing documentation for 2023
The Ministry of Finance released guidelines on the content of transfer pricing documentation for 2023.
April 30, 2024
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OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples
The OECD released a consolidated commentary to Pillar Two global anti-base erosion (GloBE) rules.
April 30, 2024
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Poland: Draft bill implementing Pillar Two global minimum tax published
Provides for an income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profit rule
April 29, 2024
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OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
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Germany: Draft bill for Annual Tax Act 2024 includes Pillar Two changes, other tax developments
Recent tax developments in Germany
April 25, 2024
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Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance
Tax Tribunal decision
April 25, 2024
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Netherlands: Public country-by-country reporting implemented
Public CbC reporting rules apply to financial years starting on or after 22 June 2024.
March 29, 2024
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Luxembourg: Guidance under Pillar Two law relating to inclusion of deferred tax assets and liabilities in computing ETR
Clarifications with respect to Article 53 of the Pillar Two law enacted in December 2023
March 28, 2024
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Netherlands: Interest deduction denied under fraud provision of corporate income tax law (Supreme Court decision)
A Supreme Court decision concerning whether interest deduction may be denied under fraud provision of corporate income tax law
March 27, 2024
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Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules
Legislative and revenue practice changes that may have an impact for funds and the asset management industry
March 25, 2024
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Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules
Consultation on primary legislation closes 16 April 2024, and consultation on subordinate legislation closes 16 May 2024.
March 22, 2024
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Finland: Legislation implementing Pillar Two global minimum tax
New legislation effective 1 January 2024 and introduces a Finnish domestic minimum top-up tax (DMTT)
March 21, 2024
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OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
Latest developments include BEPS initiatives, tax transparency efforts and other G20 tax deliverables
February 29, 2024
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Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament
Legislation introduces a so-called “top-up tax”
February 23, 2024
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KPMG report: Overview and initial observations on Pillar One – Amount B
Overview of the OECD report on Amount B and initial observations on how multinationals can respond
February 21, 2024
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EU: Updates to list of non-cooperative jurisdictions
EU blacklist now consists of 12 jurisdictions
February 21, 2024
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KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
February 21, 2024
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Nigeria: Migration of electronic platform for filing transfer pricing returns and country-by-country notifications
Taxpayers have until 30 June 2024 to fulfill all pending filing obligations relating to filings on TaxPro-Max.
February 20, 2024
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Sweden: European Commission opens State aid investigation into non-food biogas and bio-propane tax exemption schemes
Investigation follows the General Court's annulment of two previous EC decisions approving the tax exemptions
January 30, 2024
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Germany: Final guidance on CFC rules, other tax developments
Final guidance on application of the Foreign Transactions Tax Act (FTTA)
January 30, 2024
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OECD: Aggregated ICAP statistics
Key takeaways from the statistics
January 29, 2024
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Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion
Hybrid mismatch rules largely follow the OECD hybrid mismatch and branch mismatch rules from Action 2
January 29, 2024
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OECD: Comments on public consultation on model treaty commentary on extractible natural resources
Comments received on public consultation document on proposed changes to commentary on Article 5 of the OECD Model Tax Convention
January 22, 2024
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Italy: Procedure for obtaining hybrid mismatch penalty protection
Rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence
January 19, 2024
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