TaxNewsFlash
Latest tax developments being reported by KPMG member firms from around the globe
Recent Articles
June 2023
8 Jun - Liechtenstein: Consultation draft for implementation of Pillar Two global minimum tax
6 Jun - Germany: Interim findings and outcomes from mandatory disclosure rules (DAC6) reporting
6 Jun - Luxembourg: Draft law implementing DAC7
6 Jun - Switzerland: Consultation on draft law implementing Pillar Two global minimum tax
5 Jun - Netherlands: Bill implementing Pillar Two presented to Lower House of Parliament
May 2023
30 May - UK: Update on mandatory disclosure rules (DAC6), now effective
24 May - EU: Update on DAC7 implementation (May 2023)
22 May - New Zealand: May 2023 Tax Bill includes Pillar Two global minimum tax rules
19 May - EU: Action seeking annulment of EU minimum tax directive (EU General Court)
9 May - Netherlands: New guidance on mandatory disclosure rules (DAC6)
8 May - KPMG report: Progress on improving mutual agreement procedure
4 May - Luxembourg: European Commission erred in finding grant of State aid (CJEU Advocate General opinion)
4 May - Malta: Updated FAQs with further clarifications on DAC6 notice requirements for intermediaries
April 2023
28 Apr - Japan: 2023 tax reform includes income inclusion rule, CFC regime
20 Apr - EU: European Commission adopts DAC7 for exchange of information with non-EU countries
20 Apr - Italy: Draft legislation for implementation of DAC7
20 Apr - Kenya: Intention to adopt Pillar Two global minimum tax announced
20 Apr - Uganda: 2023 tax bill includes proposed digital service tax
20 Apr - United Nations: Revised subject-to-tax-rule proposal approved at tax committee meeting
6 Apr - Bahamas: Economic substance legislation and guidance notes introduced
5 Apr - Ireland: Draft legislation on implementation of Pillar Two global minimum tax
5 Apr - Estonia: Guidance on tax defensive measures relating to non-cooperative jurisdictions
5 Apr - Canada: Preparing for excessive interest and financing expenses limitation (EIFEL) legislation
4 Apr - EU: Updated State aid guiding templates
3 Apr - UK: Implementation of Pillar Two global minimum tax under Spring Finance Bill 2023
March 2023
29 Mar - Vietnam: MAAC signed, intention to implement Pillar Two global minimum tax
23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax
23 Mar - Sweden: Proposed additions to interim report on implementation of EU global minimum tax directive
23 Mar - Malta: Clarifications on DAC6 notification requirements for intermediaries
22 Mar - Spain: Public consultation on Pillar Two global minimum tax
20 Mar - Australia: Changes to interest limitation rules
16 Mar - OECD: Public consultation meeting on implementation under Pillar Two
15 Mar - EU: Temporary State aid rules adopted to support green transition
14 Mar - Thailand: Measures to support implementation of Pillar Two global minimum tax rules
10 Mar - Cyprus: Frequently asked questions on transfer pricing documentation rules
10 Mar - Luxembourg: Draft legislation for implementation of public country-by-country reporting
6 Mar - Hong Kong: Instrument of ratification of MLI deposited with OECD
February 2023
20 Feb - UK: Guidance under new mandatory disclosure rules
16 Feb - OECD: Comments on public consultation documents on implementation under Pillar Two
8 Feb - EU: Notice by EC to 14 member states of noncompliance with transposition of DAC7
8 Feb - Sweden: Interim report on implementation of EU global minimum tax directive
7 Feb - Romania: New reporting obligations for digital platform operators (DAC7)
3 Feb - KPMG report: Comments on public consultation documents on implementation under Pillar Two
2 Feb - KPMG report: U.S. accounting questions related to new GloBE rules
2 Feb - OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules
January 2023
30 Jan - EU: European Commission public consultation on DAC7 implementing regulation
30 Jan - OECD: Comments on public consultation document on Amount B under Pillar One
30 Jan - Spain: Public consultation on changes to criteria for non-cooperative jurisdictions
25 Jan - KPMG report: Comments on public consultation document on Amount B under Pillar One
24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One
20 Jan - KPMG report: Comments on public consultation document on withdrawal of DSTs under Pillar One
20 Jan - KPMG report: Where next for Amount B?
18 Jan - OECD: Revenue gains from BEPS 2.0 predicted to be higher than previously expected
17 Jan - Czech Republic: Guidance provided in Q&As on new reporting obligation under DAC7
13 Jan - OECD: Manal Corwin appointed new Director of its Centre for Tax Policy and Administration
11 Jan - EU: Update on DAC7 implementation
10 Jan - Bulgaria: Changes in VAT law, including reporting of data regarding cross-border payments
2022 Articles
December 2022
22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)
22 Dec - Spain: Guidance on online “intermediation” subject to digital services tax
21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis
19 Dec - Colombia: Tax reform measures include 15% minimum tax, surcharges, digital services tax
16 Dec - Belgium: New obligations of digital platform operators (DAC7)
16 Dec - Luxembourg: 2023 budget law passed by Parliament includes reverse hybrid rule changes
16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax
16 Dec - EU: Council adopts EU minimum tax directive
15 Dec - Mexico: Limitation on deductibility of net interest held valid (court decision)
14 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5
13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)
9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis
9 Dec - Slovakia: Public country-by-country reporting implemented
9 Dec - UK: Report of national audit office on operation and implementation of digital services tax
8 Dec - OECD: Public consultation document on Amount B under Pillar One
6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda
6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed
6 Dec - Romania: Public country-by-country reporting implemented
1 Dec - Finland: Clarifications on DAC7 reporting obligations
1 Dec - Spain: Reverse hybrid mismatch rules introduced
1 Dec - United Nations: Resolution to develop new international tax cooperation framework
November 2022
30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced
29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics
22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021
22 Nov - EU: Public country-by-country reporting implementation summary
17 Nov - Argentina: Update on ratification of MLI
16 Nov - Denmark: DAC7 guidance
10 Nov - United States: Corporate Alternative Minimum Tax considerations and FAQs
9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)
3 Nov - Finland: Draft legislation to implement DAC7
3 Nov - Hungary: Draft legislation to implement public country-by-country reporting
October 2022
27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget
25 Oct - Netherlands: Consultation on implementation of Pillar Two rules
20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive
19 Oct - KPMG report: Initial observations of OECD report on tax incentives and the global minimum tax
18 Oct - Mexico: Update on ratification of MLI
17 Oct - KPMG report: Comments in response to EC public consultation on the SAFE initiative
17 Oct - South Africa: MLI to enter into force 1 January 2023
14 Oct - OECD: Updated guidance on implementation of country-by-country reporting
14 Oct - Australia: New income tax treaty with Iceland signed, incorporating BEPS recommendations
13 Oct - Australia: Consultation paper on BEPS 2.0
13 Oct - Belgium: Tax proposals in budget 2023-2024 include 15% minimum tax
11 Oct - Hong Kong: Proposed incorporation of MLI into domestic law
7 Oct - Malaysia: Tax proposals in budget for 2023, including domestic minimum top-up tax
6 Oct - OECD: Report on tax incentives and the global minimum tax
September 2022
30 Sep - OECD: Inclusive Framework on BEPS meeting scheduled for 6 - 7 October 2022
28 Sep - Germany: Draft legislation on submission of transfer pricing documentation in tax audit
20 Sep - United States: SEC signals support for country-by-country reporting
19 Sep - Belgium: DAC6 legislation held invalid, questions raised to CJEU (Constitutional Court decision)
August 2022
26 Aug - Bulgaria: MLI ratified
26 Aug - Hong Kong: Implementation of Pillar Two deferred to 2024 at the earliest
25 Aug - OECD: Comments on progress report on Amount A of Pillar One
23 Aug - KPMG report: Implementation of ATAD I and II by EU Member States
19 Aug - KPMG report: Comments on progress report on Amount A of Pillar One
19 Aug - KPMG report: European Commission business tax agenda
12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes
12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information
10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures
5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency
July 2022
29 Jul - Mauritius: Tax measures in Finance Bill 2022 include domestic top-up tax
27 Jul - OECD: Progress on harmful tax practices
26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw
22 Jul - Ireland: BEPS 2.0 implications for aviation sector
20 Jul - UK: Draft legislation to implement Pillar Two published
20 Jul - Greece: Legislation incorporating ATAD measures for reverse hybrid instruments
18 Jul - KPMG report: The diverging paths of Pillars One and Two
18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency
14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council
12 Jul - Netherlands: New decree on profit attribution to permanent establishments
11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation
June 2022
30 Jun - Australia: Treatment of U.S. GILTI under hybrid mismatch rules
29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test
29 Jun - Slovakia: Implementation of EU directive on reporting obligations of digital platforms (DAC7)
27 Jun - UK: Background and implications of delayed implementation of Pillar Two
17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting
16 Jun - KPMG report: Update on tax control framework requirements
15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One
14 Jun - UK: Implementation of Pillar Two delayed
14 Jun - OECD: Tax transparency in Africa 2022
10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One
10 Jun - Luxembourg: New income tax treaty with UK is signed
8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021
7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country
May 2022
27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation
25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One
24 May - EU: Status regarding proposal for EU minimum tax directive
20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One
17 May - Luxembourg: FAQ on mandatory disclosure rules (DAC6)
16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax
10 May - Poland: Mandatory disclosure requirement deadlines for domestic arrangements remain extended
6 May - Malta: FAQs on mandatory disclosure rules (DAC6)
6 May - Netherlands: Considerations for companies in scope of Pillar Two rules
6 May - New Zealand: Consultation on implementation of Pillar Two rules
6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation
5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico
5 May - Canada: Draft hybrid mismatch legislation
4 May - Nigeria: Summary of tax transparency reporting developments
4 May - OECD: Tax transparency in Latin America 2022
3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One
3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One
3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update
2 May - UK: Additional compliance requirements under hybrid mismatch rules
April 2022
22 Apr - Gibraltar: Exemption regime for royalties constitutes unlawful state aid (EU General Court)
22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
14 Apr - OECD: Comments on implementation framework of global minimum tax
14 Apr - KPMG report: Comments on implementation framework of global minimum tax
14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax
14 Apr - OECD: Extractives exclusion under Amount A of Pillar One; public consultation
12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines
6 Apr - KPMG report: Comments in response to EU public consultation on “Unshell” Directive proposal
5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)
4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested
March 2022
22 Mar - Indonesia: Guidance on coordination of CFC rules with taxation of dividends
16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive
14 Mar - OECD: Commentary on Pillar Two model rules for domestic implementation of 15% global minimum tax
8 Mar - KPMG report: Comments in response to EC public consultation on proposal for minimum tax directive
8 Mar - OECD: Comments on draft model rules for tax base determinations under Pillar One Amount A
4 Mar - KPMG report: Comments on OECD’s draft rules for tax base determinations under Pillar One
Amount A
2 Mar - KPMG report: BEPS 2.0 issues and implications for Latin America
February 2022
28 Feb - KPMG report: Top concerns for tax leaders on the path forward for BEPS 2.0
28 Feb - Bahamas: Updated EU “grey list” includes Bahamas and other Caribbean countries
28 Feb - Thailand: Multilateral instrument (MLI) is signed
22 Feb - OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A
22 Feb - Thailand: Additional country-by-country reporting submission requirements
18 Feb - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One
Amount A
18 Feb - OECD: Draft rules for tax base determinations under Amount A of Pillar One; comments requested
16 Feb - Vietnam: Almost all tax treaties implicated with the signing of MLI
14 Feb - Cyprus: Protocols with Germany and Switzerland in effect; BEPS minimum standards implemented
11 Feb - Barbados: Rules requiring country-by-country reporting enacted
January 2022
21 Jan - UK: Consultation on domestic implementation of Pillar Two rules
21 Jan - UK: Pillar Two concept of international shipping and boundaries of UK tonnage tax regime
18 Jan - Switzerland: Implementation of Pillar Two global minimum tax
13 Jan - Bahrain: Country-by-country obligations extended to 28 February 2022
12 Jan - Thailand: Extended deadlines for submitting country-by-country reports
11 Jan - UK: Public consultation on implementation of Pillar Two
5 Jan - Nigeria: Country-by-country reporting requirements by branches and subsidiaries of foreign MNEs
2021 Articles
December 2021
22 Dec - EU: Directive to implement Pillar Two is proposed
22 Dec - Cyprus: Country-by-country report for 2020 is due 31 January 2022
21 Dec - OECD: Schedule for public consultations on two-pillar solution
20 Dec - OECD: Pillar Two model rules for domestic implementation of 15% global minimum tax
2 Dec - UK: Update on proposed changes regarding transfer pricing documentation
1 Dec - Bahrain: Country-by-country notifications due 31 December 2021
1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal
November 2021
29 Nov - KPMG report: EU “public” country-by-country reporting and implications for multinational groups
18 Nov - Australia: Deferral of date for filing (lodging) country-by-country reporting statements
11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting
2 Nov - Dominican Republic: Transfer pricing rules, updated compliance and documentation requirements
October 2021
20 Oct - Bahrain: Updated guidance on mutual agreement procedures
20 Oct - Thailand: Transfer pricing requirements and country-by-country reporting, effective 2021
18 Oct - Cyprus: Arrangement with United States for exchange of country-by-country reports
14 Oct - Serbia: Updated transfer pricing guidance, information for country-by-country report
13 Oct - OECD: G20 finance leaders endorse changes to global tax rules
9 Oct - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
8 Oct - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy
7 Oct - Thailand: New requirements for transfer pricing and Local file documentation
4 Oct - KPMG report: Country-by-country reporting, notification requirements per country
September 2021
August 2021
July 2021
15 Jul - Bahrain: Country-by-country reporting and notification obligations
15 Jul - Oman: Clarification of suspension of country-by-country reporting
13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021
10 Jul - G20 finance ministers conclude meeting with agreement for global minimum tax, other measures
8 Jul - Oman: Country-by-country reporting is suspended
2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
June 2021
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.