Digital Economy

KPMG TaxNewsFlash reports on the latest developments in the tax treatment of the digital economy, including digital services taxes and the taxation of online remote sales

April 2025
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Spain: Regulations under Pillar Two global minimum tax law

Implementing regulations under Law 7/2024 approved by the Cabinet

April 2, 2025

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Bulgaria: Amendments to Pillar Two law enacted

Several amendments to the Bulgarian Pillar Two legislation introduced under budget law.

April 1, 2025

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EU: Commissioner outlines EC tax priorities at 2025 EU Tax Symposium

Priorities include commitment to Pillar Two

April 1, 2025

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Finland: Guidance on Pillar Two global minimum tax

Key elements of the Minimum Tax Act and additional clarifications on general application of Pillar Two rules

April 1, 2025

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KPMG report: Overview of topics and workstreams discussed at recent meeting of UN Tax Committee

A KPMG report of the main items discussed at the UN Tax Committee and their potential implications for taxpayers.

April 1, 2025

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Qatar: Introduction of Pillar Two global minimum tax rules

Introduces an income inclusion rule (IIR) and a domestic minimum top-up tax (DMTT) for fiscal years starting from January 1, 2025

April 1, 2025

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UK: 2025 Finance Act enacted, includes changes to UK Pillar Two rules

UTPR introduced for periods beginning on or after December 31, 2024

April 1, 2025

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    Latest tax developments from the United States and from KPMG member firms around the globe

    March 2025
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    Japan: 2025 tax reform bills, including Pillar Two rules, passed by Parliament

    Measures include introduction of undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT)

    March 31, 2025

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    Iceland: New reporting obligations for digital platform operators effective January 1, 2025

    Reporting platforms are required to register with the Icelandic tax authorities, except if they are already registered in one of the states of the European Economic Area.

    March 25, 2025

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    KPMG article: Effect of digital transformation on transfer pricing

    Examples of how digital transformation is creating transfer pricing issues for multinational enterprises

    March 18, 2025

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    Italy: Ministerial Decree on GloBE information return (GIR) notifications

    The actual notification form and further details on the submission will be clarified by the revenue agency.

    March 18, 2025

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    Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual

    Version 1.0 released on March 9, 2025

    March 17, 2025

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    Switzerland: Implementation of cryptoasset reporting framework MCAA

    Intends to maintain tax transparency standards amidst the expanding cryptoasset market

    March 17, 2025

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    Turkey: Announcement that Amount B under Pillar One will not be applied

    Official announcement on March 7, 2025

    March 17, 2025

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    EU: Council reaches political agreement on DAC9

    Member states need to implement the directive into national legislation by December 31, 2025.

    March 11, 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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    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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    Greece: Streamlined process for reporting withheld taxes and digital transactions fees; incentives for audiovisual projects

    Streamlined process effective for payments made on or after December 1, 2025

    March 3, 2025

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    Mozambique: Tax proposals announced by president in inauguration speech

    Including plans for taxing digital transactions

    March 3, 2025

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      Taxation of the digitalized economy

      Developments summary

      Updated January 30, 2025

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      February 2025
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      OECD: Report to G20 Finance Ministers and Central Bank Governors, recent developments in international tax cooperation

      Recent developments include implementation of BEPS minimum standards and Two-Pillar solution

      February 27, 2025

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      Slovakia: Proposed amendments to implement exchange of Pillar Two information between EU member states (DAC9)

      Minister of Finance announced amendments on January 20, 2025

      February 27, 2025

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      Denmark: Proposed amendments to Pillar Two law

      Comments are due by March 3, 2025.

      February 26, 2025

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      EU: Public meeting of European Parliament Subcommittee on Tax Matters with European Commissioner responsible for tax

      EU will not withdraw from Pillar Two agreement and remains committed to reaching Pillar One agreement

      February 26, 2025

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      White House announces directive to counter digital service taxes (DSTs)

      President Trump signed a memorandum to respond to the enactment by foreign governments of DSTs.

      February 24, 2025

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      OECD: Consolidated report on Amount B

      Incorporates materials on Amount B released from February 2024 until December 2024

      February 24, 2025

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      Niger: VAT obligations for digital platforms from January 1, 2025

      Obligations of both local and foreign platforms

      February 21, 2025

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      Israel: Draft regulations on withholding tax for digital asset transactions

      Regulations proposed to become effective July 1, 2025

      February 20, 2025

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      Poland: List of jurisdictions with qualified status for Pillar Two purposes

      List applies for purposes of local implementation of Pillar Two rules

      February 20, 2025

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      Kenya: Legislation replacing digital services tax with significant economic presence tax, implementing Pillar Two rules

      Legislation also includes withholding tax and VAT changes

      February 13, 2025

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      Czech Republic: Individual income tax exemption for income from transfer of cryptoassets passed by upper house of Parliament

      Legislation now awaits president’s signature

      February 13, 2025

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      Sweden: Government report to Parliament on EU proposal for exchange of Pillar Two information between EU member states (DAC9)

      Report regarding changes potentially required for implementation in Sweden

      February 13, 2025

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      UAE: Legislation implementing Pillar Two global minimum tax rules

      Effective for financial years beginning on or after January 1, 2025

      February 12, 2025

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      France: Tax measures in Finance Act 2025

      Includes direct and indirect tax measures affecting companies

      February 11, 2025

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      Colombia: Reporting obligations for digital platform operators implemented

      Resolution 199 of 2024

      February 11, 2025

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      Italy: List of jurisdictions with transitional qualified status for Pillar Two purposes

      List applies for purposes of local implementation of Pillar Two rules

      February 7, 2025

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      UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025

      Including incorporation of provisions from OECD June 2024 Administrative Guidance

      February 7, 2025

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      UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules

      Last consultation before guidance manual will be published in late spring 2025

      February 6, 2025

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        E-invoicing developments timeline

        Tax administration developments in e-invoicing, digital reporting, and real-time reporting

        Updated January 2025

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        January 2025
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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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        Kenya: Excise duty on services provided by nonresidents through digital platforms

        Revision significantly expands the tax base

        January 29, 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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        Philippines: Application of VAT on digital services

        Digital services will be taxed at a 12% rate when used or consumed in the Philippines.

        January 23, 2025

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        Slovakia: Draft legislation implementing directive on tax transparency rules for cryptoasset service providers (DAC8)

        Rules would become effective January 1, 2026

        January 23, 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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        Italy: Budget law expands scope of digital service tax

        Changes to DST threshold

        January 10, 2025

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        Final and proposed regulations: Classification of digital content and cloud transactions for purposes of international provisions of the Code

        Comments requested under Notice 2025-6 on extending rules to all provisions of the Code

        January 10, 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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        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

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          December 2024
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          Notice 2025-7: Temporary relief for making adequate identification of units of digital assets held in broker’s custody

          Allows reliance on alternative methods for making an adequate identification during the period beginning on January 1, 2025, and ending on December 31, 2025

          December 31, 2024

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          Information reporting by non-custodial brokers of digital asset transactions

          Final regulations requiring information reporting by non-custodial digital asset brokers and transitional relief under Notice 2025-3

          December 27, 2024

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          Hong Kong: Draft legislation implementing Pillar Two global minimum tax rules

          Draft legislation will be presented to the Legislative Council on January 8, 2025.

          December 27, 2024

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          Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules

          Tax measures effective from November 12, 2024

          December 27, 2024

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          Japan: Outline of 2025 tax reform proposals, including new Pillar Two rules

          Proposals include introduction of undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT)

          December 27, 2024

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          Peru: Regulation implementing VAT compliance obligations for nonresident digital services providers

          Regulation is effective January 1, 2025.

          December 27, 2024

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          Luxembourg: Overview of tax measures for 2025, including amended Pillar Two law

          Comprehensive overview of the key tax measures for 2025

          December 20, 2024

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          KPMG report: Proposed adoption of Amount B in the United States

          Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.

          December 19, 2024

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          OECD: Fact sheets and pricing tool for implementation of Amount B simplified approach

          Fact sheets provide overview of Amount B mechanics, Pricing Automation Tool computes Amount B return for in-scope tested parties

          December 19, 2024

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          Hungary: Changes to autumn tax package, including Pillar Two rules, agreed by Parliament

          Approved version narrows the scope of data that companies subject to global minimum tax are required to report by the end of the year.

          December 19, 2024

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          Canada: Large businesses must register for digital services tax by January 31, 2025

          Affected businesses that earn specific kinds of online revenues meeting certain thresholds must register by January 31, 2025

          December 19, 2024

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          Sri Lanka: Tax reform proposals presented to Parliament include VAT on nonresident digital service providers

          Proposals presented to Parliament by the president on December 18, 2024

          December 19, 2024

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          Notice 2025-4: Application of Pillar One Amount B simplified and streamlined approach

          Treasury and IRS announce intention to issue proposed regulations applicable to tax years beginning on or after January 1, 2025.

          December 18, 2024

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          Netherlands: Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules

          In total, 11 tax bills and an amending act were passed.

          December 18, 2024

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          Bahrain: Pillar Two global minimum tax implementing regulations

          The regulations prescribe detailed rules, conditions, and procedures for implementation and enforcement of the Pillar Two global minimum tax.

          December 16, 2024

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          Gibraltar: Draft legislation implementing Pillar Two global minimum tax rules

          Top-up tax would apply for financial years starting on or after December 31, 2023

          December 16, 2024

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          France: Guidance on Pillar Two global minimum tax filing and notification obligations

          Decree specifying Pillar Two filing and notification obligations published on December 5, 2024.

          December 12, 2024

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          EU: ECOFIN report on various tax initiatives

          Report includes updates on Unshell Directive, Transfer Pricing Directive, BEFIT Directive, and DAC9 proposals

          December 12, 2024

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          Malaysia: Guidance on Pillar Two global minimum tax

          The guidance covers scope, filing obligations, transitional penalty relief, and safe harbors.

          December 12, 2024

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          Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent

          Legislation received Royal Assent on December 10, 2024.

          December 11, 2024

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          Italy: New VAT place of supply rules for virtual events

          The new rules are effective as of January 1, 2025.

          December 10, 2024

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          Belgium: Proposed changes to various automatic exchange of information rules (DAC6 and DAC7)

          Changes are expected to be adopted before end of the year

          December 6, 2024

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          Netherlands: Guidance on how Pillar One Amount B will affect domestic taxpayers

          Guidance becomes effective January 1, 2025

          December 5, 2024

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          KPMG report: Update on future of BEPS guidance from OECD

          Noel Maher, Tax Policy Adviser from the OECD, discussed ongoing work at the OECD at KPMG-sponsored conference

          December 4, 2024

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          Spain: Legislation implementing Pillar Two global minimum tax passed by lower house of Parliament

          The legislation also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.

          December 4, 2024

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          Netherlands: Draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8)

          A new draft bill implementing EU Directive 2023/2226 (DAC8), aimed at increasing transparency regarding cryptoasset ownership.

          December 4, 2024

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          Australia: Parliament passes Pillar Two minimum tax bills

          The legislation now awaits Royal Assent.

          December 2, 2024

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          Australia: Parliamentary committee recommends implementing digital services tax

          Report of Australian Parliament Joint Select Committee on Social Media and Australian Society

          December 2, 2024

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            November 2024
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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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            Australia: Consultation on cryptoasset reporting framework (CARF) and CRS amendments

            The consultation closes January 24, 2025.

            November 22, 2024

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            Brazil: Consultation on draft guidance implementing cryptoasset reporting

            The consultation will run from November 7, 2024, to December 6, 2024.

            November 22, 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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            Colombia: Tax authority issues guidance on application significant economic presence rule

            Tax authority’s ruling addresses several taxpayer questions regarding the SEP provisions

            November 20, 2024

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            Germany: Draft law introduced to implement DAC8 regulations and amend CRS

            Aims to integrate DAC8 requirements into German national law by December 31, 2025

            November 20, 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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            Lithuania: Proposed tax changes concerning double taxation, DAC8, submission of tax information, and solidarity contribution

            The Lithuanian government and various agencies have proposed several tax-related changes aimed at improving compliance, preventing tax evasion, and aligning with international standards.

            November 19, 2024

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            Hungary: Proposed extension of retail sales tax to online marketplaces

            Proposal would include nonresident or resident platform operators that provide an online marketplace for sellers engaged in retail activities

            November 15, 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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            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

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              October 2024
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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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              Mexico: New VAT withholding requirement for platforms facilitating the sales of goods for nonresidents

              Requires digital platforms that act as intermediaries between third parties to withhold 100% of the VAT corresponding to the sales of goods

              October 25, 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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              Italy: Proposal to remove digital service tax revenue thresholds

              The proposal would be effective from January 1, 2025.

              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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              Mexico: Tax authority clarifies definition of digital intermediation services

              Amendment to the definition of intermediation of digital services for purposes of the Mexican VAT law

              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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              Chile: Withholding on payments to U.S. residents; reporting by digital platforms; other direct and indirect tax developments

              Oficio No. 1763/2024 provides guidance on withholding under Chile-U.S. income tax treaty

              October 18, 2024

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              UK: HMRC outreach to businesses in technology, media, and telecommunications sector regarding VAT compliance

              Sellers of telecommunications, broadcasting, and electronically supplied services to consumers in the UK are liable to register for, collect, and remit VAT.

              October 18, 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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              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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              Chile: New reporting and VAT obligations for digital platforms, remote sellers

              While the bill still needs to go through some minor legislative steps before officially becoming Law, no material changes are expected.

              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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              Mexico: Rules for collecting tax on hosting services on digital platforms (Veracruz)

              The rules apply to individuals and legal entities that intervene in the collection of the consideration for hosting services by digital means.

              October 9, 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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              Philippines: New law imposes VAT on cross-border provision of digital services

              The law imposes a 12% VAT on digital services consumed in the Philippines.

              October 3, 2024

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              OECD: User guides for XML schemas for cryptoasset reporting framework (CARF) and CRS amendments

              The schemas facilitate exchanges of information between tax administrations.

              October 3, 2024

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              Spain: Consultation on draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8)

              The rules are proposed to be effective January 1, 2026.

              October 3, 2024

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              Ethiopia: New VAT rules for nonresident digital services providers

              Proclamation No. 1341/2024 was approved by the House of Peoples’ Representatives of Ethiopia.

              October 2, 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

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                September 2024
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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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                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 report: Draft instructions for Form 1099-DA, Digital Asset Proceeds from Broker Transactions

                Overview of draft instructions as they relate to the final U.S. broker digital asset reporting regulations

                September 19, 2024

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                KPMG report: Treatment of nonfungible tokens under the final broker reporting regulations

                Overview of NFTs in final regulations

                September 19, 2024

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                U.S. House Republican leadership, Ways and Means members express opposition to Pillar Two deal in letter to OECD

                Sent a letter to the OECD Secretary-General expressing their opposition

                September 18, 2024

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                Saudi Arabia: Proposed amendments to VAT regulations, including expansion of VAT obligations of marketplaces

                The Zakat, Tax and Customs Authority launched a public consultation on proposed amendments to the value added tax regulations.

                September 13, 2024

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                Switzerland: Announcement regarding implementation of income inclusion rule

                Effective January 1, 2025, to complement the domestic minimum top-up tax

                September 13, 2024

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                Sweden: Proposed amendments to Pillar Two global minimum tax rules

                Proposed amendments would introduce elements of the OECD Administrative Guidance

                September 13, 2024

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                Peru: VAT on cross-border provision of digital services (updated)

                Implementation of the rules delayed to December 1, 2024

                September 13, 2024

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                Finland: Consultation on proposed amendments to Pillar Two global minimum tax rules

                Proposed amendments would apply retroactively to financial years beginning on or after January 1, 2024.

                September 13, 2024

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                Kazakhstan: VAT on foreign suppliers of digital products

                Article 779 of the Kazakhstan Tax Code imposes 12% VAT on foreign suppliers of goods and services provided electronically to individuals in Kazakhstan.

                September 11, 2024

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                Bahrain: Legislation implementing Pillar Two global minimum tax rules

                Key features of the new law and an overview of how the domestic minimum top-up tax is calculated

                September 5, 2024

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                Peru: Guidance on registration of nonresident withholding agents of VAT on cross-border provision of digital services

                Rules for registration in the single taxpayer registry of nonresidents designated as withholding or collection agents of VAT on the cross-border provision of digital services

                September 4, 2024

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                Belgium: Prepayment system for Pillar Two taxes now operational

                Prepayment system for domestic minimum top-up tax and income inclusion rule top-up tax is operational as of September 2, 2024.

                September 3, 2024

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                  August 2024
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                  New Zealand: August tax bill includes implementation of cryptoasset reporting framework (CARF)

                  Taxation (Annual Rates for 2024-25, Emergency Response and Remedial Matters) Bill

                  August 30, 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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                  Peru: VAT on cross-border provision of digital services

                  Implementation of the rules delayed to December 1, 2024

                  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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                  Switzerland: Consultation on determination of partner states for AEOI concerning cryptoassets

                  The Federal Tax Administration announced a consultation to determine partner states for the automatic exchange of information on cryptoassets.

                  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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                  Serbia: Amendments to e-invoicing rulebook

                  Amended rulebook generally applies as of September 1, 2024

                  August 21, 2024

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                  KPMG report: Information reporting for U.S. digital asset brokers

                  Requirements for a digital asset broker to file information returns and furnish payee statements that report gross proceeds on sales of digital assets

                  August 21, 2024

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                  Channel Islands: Pillar Two draft legislation published (Jersey)

                  Scheduled for debate in Jersey’s Parliament on October 1, 2024

                  August 19, 2024

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                  KPMG report: Documentation rules under final digital asset reporting regulations

                  Overview of tax documentation required to be collected by U.S. digital asset brokers under final U.S. broker digital asset reporting regulations

                  August 12, 2024

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                  IRS releases draft updated Form 1099-DA for digital assets proceeds from broker transactions, requests comments

                  New draft of Form 1099-DA reflects final regulations for custodial broker reporting and includes transitional relief

                  August 9, 2024

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                  Ghana: Measures related to tax administration, digital solutions, indirect tax in 2024 mid-year budget review

                  Focuses on tax administration measures to support effective implementation of tax measures already enacted

                  August 7, 2024

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                  Korea: Further proposed amendments to Pillar Two rules

                  The Ministry of Economy and Finance announced further proposed amendments to the Korean Pillar Two global anti-base erosion minimum tax rules.

                  August 6, 2024

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                  EU: Public consultation on template and formats for public country-by-country (CbC) reports

                  Feedback must be submitted by August 29, 2024

                  August 2, 2024

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                    July 2024
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                    Switzerland: Draft guidelines on platform rules for goods effective 2025

                    Draft guidelines currently open for consultation until August 23, 2024

                    July 30, 2024

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                    KPMG report: State and local tax, technology-related developments (table, second quarter 2024)

                    Covers topics such as web-based services, data center exemptions, streaming services, and telecommunications services

                    July 29, 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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                    KPMG report: Planning implementation of broker digital asset reporting regulations

                    Key timeline considerations for brokers subject to a reporting requirement under final regulations

                    July 24, 2024

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                    Chile: Optional regime for substitute tax for final taxes

                    Law No. 21,681 creates an emergency fund and provides other relief for communities in the Valparaíso Region affected by a major fire in February 2024

                    July 23, 2024

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                    KPMG report: Employee data reporting under Pillar Two

                    A KPMG report that discusses how correctly reporting employee numbers, locations, and costs will benefit multinational enterprises under Pillar Two.

                    July 22, 2024

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                    Canada: Digital platforms must report seller information by January 31, 2025

                    New tax reporting requirements, effective from the 2024 calendar year

                    July 22, 2024

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                    Mexico: New requirements for registering foreign digital service providers

                    Two new requirements for registering foreign digital services providers in Mexico

                    July 16, 2024

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                    Azerbaijan: Registration portal for VAT on cross-border provision of digital services

                    Registration is currently optional for taxpayers.

                    July 16, 2024

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                    KPMG report: Final regulations on information reporting on digital asset transactions

                    The U.S. Treasury Department and IRS issued final regulations on digital asset tax information reporting requirements.

                    July 12, 2024

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                    OECD: Consultation on GloBE information return filing standard

                    The OECD released a draft user guide for the GloBE information return filing standard for consultation.

                    July 12, 2024

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                    Australia: Draft legislation implementing Pillar Two global minimum tax rules introduced in Parliament

                    Draft legislation was referred to the Senate Economics Legislation Committee

                    July 9, 2024

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                    Canada: Digital services tax now in effect

                    Affected businesses will have to register with the CRA by January 31, 2025

                    July 8, 2024

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                    Gibraltar: Additional tax proposals in 2024 budget, including update to Pillar Two rules

                    Minister for Justice, Trade and Industry addressed the Gibraltar parliament

                    July 3, 2024

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                    Belgium: Extended deadline for GloBE registration for groups not intending to prepay to 16 September 2024

                    Deadline remains unchanged for groups that intend to prepay

                    July 2, 2024

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                    Australia: ATO update on implementation of Pillar Two global minimum tax rules

                    Australian-specific administration and interpretation issues

                    July 1, 2024

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                      June 2024
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                      Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

                      Regarding information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

                      June 28, 2024

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                      Germany: Draft bill for Annual Tax Act 2024 published, includes Pillar Two changes; other tax developments

                      Recent tax developments in Germany

                      June 28, 2024

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                      KPMG report: Accounting for income tax implications of Pillar Two GloBE top-up taxes

                      A KPMG report that discusses how implementing the new rules and determining the appropriate accounting impacts may be challenging.

                      June 25, 2024

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                      Canada: Outstanding tax measures enacted, including Pillar Two, EIFEL, hybrid mismatch, clean economy, and GAAR

                      Tax measures previously proposed in the federal budgets of 2022, 2023, and 2024, as well as the 2023 federal economic update

                      June 24, 2024

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                      KPMG report: OECD unveils further details on Amount B simplified approach

                      The OECD published additional guidance on key definitions related to Amount B.

                      June 18, 2024

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                      OECD: Further guidance on Pillar One Amount B and Pillar Two global minimum tax

                      Further information relating to Amount B of Pillar One and the global minimum tax under Pillar Two

                      June 17, 2024

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                      Poland: Postponement of e-invoicing mandate signed by president

                      Postponed to February 1, 2026

                      June 11, 2024

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                      UN: Proposed zero draft terms of reference for UN framework convention on international tax cooperation

                      Written comments are due by 21 June 2024.

                      June 10, 2024

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                      Senegal: Changes to VAT on cross-border provision of digital services, now effective from 1 July 2024

                      Rules are now going to be effective from 1 July 2024

                      June 6, 2024

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                      Australia: Reporting exemption for specified transactions for electronic distribution platform operators

                      The ATO registered a legislative instrument that exempts EDP operators from having to include specified classes of transactions in their reporting.

                      June 6, 2024

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                      Italy: Implementation of Pillar Two transitional safe harbors

                      Transitional country-by-country (CbC) reporting safe harbors for groups subject to the Pillar Two global minimum tax

                      June 4, 2024

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                      KPMG report: Assessing the impact of Amount B

                      Unexpected outcomes and potential challenges that businesses may need to consider

                      June 3, 2024

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                        May 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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                        Italy: Certain additional obligations on online service providers not allowed under EU law (CJEU judgment)

                        Certain additional obligations under Italian law on providers of online intermediation services and search engines are precluded under EU law.

                        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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                        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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                        Spain: Consultation on draft legislation implementing Pillar Two global minimum tax

                        Comments accepted until May 31, 2024

                        May 23, 2024

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                        Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules

                        KPMG tax professionals provided a submission to Treasury on the primary legislation

                        May 23, 2024

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                        Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax

                        Several cantons have changed their tax rates in response to enactment of Pillar Two global minimum tax

                        May 22, 2024

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                        Belgium: GloBE registration requirements for multinational and large domestic groups

                        Responsibility lies with Belgian ultimate parent entity or Belgian constituent entity

                        May 22, 2024

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                        Australia: Proposed exemptions from sharing economy reporting regime

                        Proposed exemptions would apply even to supplies that create a GST liability for the supplier or electronic distribution platform

                        May 21, 2024

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                        Kenya: Tax proposals in Finance Bill, 2024 include implementation of Pillar Two global minimum tax

                        Changes to tax framework

                        May 16, 2024

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                        Costa Rica: Public consultation on draft law introducing reporting obligations for digital platform operators

                        The aim is to adopt the OECD’s Model Reporting Rules for digital platforms.

                        May 13, 2024

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                        Canada: Sales tax changes target digital products and services (British Columbia)

                        Changes apply retroactively to 2013 and broaden certain definitions under the provincial sales tax rules

                        May 10, 2024

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                        Brazil: Draft regulations to introduce new dual VAT regime

                        The Brazilian government presented to Congress the regulations to introduce the new dual VAT regime under the tax reform bill.

                        May 6, 2024

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                        Belgium: Amendments to Pillar Two global minimum tax rules

                        The Belgian Parliament adopted amendments to the Pillar Two global minimum tax rules that were adopted in December 2023.

                        May 3, 2024

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                        Norway: Pillar Two global minimum tax implemented in Supplementary Tax Act

                        Norway implemented the Pillar Two global minimum tax rules in the Supplementary Tax Act, which became effective 1 January 2024.

                        May 2, 2024

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                          April 2024
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                          Australia: Amendments to superannuation system

                          A key amendment in the amending regulation is the addition of a new paragraph into the definition of “superannuation system”.

                          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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                          KPMG reports: Alabama, Arkansas, Colorado, South Carolina, Tennessee, Virginia

                          KPMG This Week in State Tax focuses on recent state and local tax developments.

                          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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                          Germany: VAT treatment of vouchers (CJEU judgment)

                          Judgment clarifies when a voucher qualifies as a single-purpose voucher, and discusses the VAT consequences of the resale of a multi-purpose voucher

                          April 23, 2024

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                          Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules

                          KPMG tax professionals provided a submission to Treasury

                          April 19, 2024

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                          KPMG report: Initial analysis of stock repurchase excise tax proposed regulations

                          A report that provides initial analysis of the proposed regulations

                          April 17, 2024

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                          KPMG report: Partnership audit rules and specific IRS forms

                          Partnership audit rules enacted by the BBA have altered how partners report and pay tax on adjustments

                          April 15, 2024

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                          Korea: Guidance regarding amendments to Pillar Two rules

                          The Ministry of Economy and Finance published regulations regarding the amendments to the Korean Pillar Two global minimum tax rules.

                          April 11, 2024

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                          KPMG report: State, local tax changes (first quarter 2024, table format)

                          Summary of state and local tax developments for the first quarter of 2024

                          April 10, 2024

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                          KPMG reports: Arizona, Kentucky, Minnesota

                          KPMG reports focus on recent state and local tax developments

                          April 8, 2024

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                          KPMG report: Global e-invoicing and digital reporting mandates

                          Review of digital reporting rules and why it’s imperative for the C-suite of global multinationals to respond

                          April 8, 2024

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                          KPMG report: Transfer pricing and ESG—improving governance by operationalizing transfer pricing

                          A report that focuses on ways multinational corporations can use operational transfer pricing as a mechanism to improve compliance

                          April 8, 2024

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                          Poland: New bill implementing reporting obligations for digital platform operators (DAC7)

                          Bill implementing Council Directive (EU) 2021/514 (DAC7)

                          April 3, 2024

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                          Sweden: VAT treatment of NFTs associated with a digital work

                          Combination of digital work's ownership and ability to verify ownership through the NFT constitutes a new service

                          April 2, 2024

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                          KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations

                          Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences

                          April 2, 2024

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                            March 2024
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                            Laos: VAT on cross-border provision of digital services

                            Provisions, effective 1 August 2024, requiring nonresident digital services providers to register for and collect value added tax

                            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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                            Chile: Tax reform bill introduces VAT liability for sales of low-value goods

                            Tax authority expected to issue further guidance to clarify the proposed regime

                            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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                            Australia: Consultation on new proposed reporting exemptions for electronic distribution platform operators

                            Consultation on a draft legislative instrument that would introduce new reporting exemptions for electronic distribution platforms operators

                            March 21, 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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                            KPMG report: Amount B compliance challenges

                            Compliance challenges associated with the Amount B consensus document

                            March 19, 2024

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                            Cyprus: Draft legislation implementing Pillar Two global minimum tax rules

                            Draft legislation would introduce IIR and UTPR for MNEs, and harmonize the tax framework with EU directive

                            March 14, 2024

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                            Malta: Guidance on implementation of Pillar Two global minimum tax

                            Guidance addresses option to defer implementation of parts of EU Directive and compliance obligation of local entities affected by EU Directive

                            March 14, 2024

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                            Jamaica: Tax measures in 2024-2025 budget

                            Proposed tax changes included in budget

                            March 14, 2024

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                            United States and Turkey announce updated digital services tax agreement

                            Summary of political agreement between United States and Turkey

                            March 12, 2024

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                            EU: VAT obligations of digital platforms pre-2015 (CJEU referral)

                            Referral from the German Federal Tax Court (BFH)

                            March 11, 2024

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                            Philippines: Proposed legislation regarding VAT on cross-border provision of digital services

                            Proposed 12% VAT on digital services consumed in the Philippines

                            March 7, 2024

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                            Angola: Revisions to VAT law, including taxation of e-commerce transactions

                            Law No. 14/23 revises the value added tax (VAT) law

                            March 6, 2024

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                            Spain: Digital platform operators must file returns under DAC7 by 8 April 2024

                            Royal Decree 117/2024 and Order HAC/72/2024 were published in the Official State Gazette.

                            March 5, 2024

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                            Poland: Bill implementing Pillar Two global minimum tax

                            The bill is expected to be passed by the Council of Ministers no earlier than in Q3

                            March 5, 2024

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                            EU: European public prosecutor's office estimates serious VAT fraud amounting to €11.5 billion

                            71% increase from 2022 report

                            March 5, 2024

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                            Morocco: VAT on cross-border provision of digital services

                            Provisions clarifying VAT obligations of nonresident digital services providers effective 1 January 2024

                            March 4, 2024

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                            Colombia: Corporate compliance for legal entities with presence in Colombia (2024)

                            Summary of the corporate, commercial, customs, and foreign exchange obligations for 2024

                            March 1, 2024

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                            Romania: Law implementing Pillar Two global minimum tax

                            Law 431/2023

                            January 16, 2024

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                              February 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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                              Republic of the Congo: VAT on cross-border provision of digital services

                              Finance Act for 2024 includes provisions requiring nonresident digital services providers to register for and collect VAT

                              February 27, 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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                              Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules

                              Proposals implementing Pillar Two global minimum tax rules for financial years starting 1 January 2025

                              February 20, 2024

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                              OECD: Report on Amount B under Pillar One

                              Simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities

                              February 19, 2024

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                              Malaysia: Updated e-invoicing guidelines, software development kit

                              The Inland Revenue Board issued an updated e-invoice guideline and e-invoice specific guideline.

                              February 16, 2024

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                              Malaysia: Final guide on transitional rules for service tax rate change on foreign digital services

                              Final guide on transitional rules for change in service tax rate on digital services provided by foreign registered persons

                              February 16, 2024

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                              France: Tax authority guidance on VAT treatment of non-fungible tokens

                              VAT rules must be applied on a case-by-case basis.

                              February 16, 2024

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                              U.S. Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

                              Extended political agreement regarding unilateral measures concerning the imposition of digital services taxes (DSTs)

                              February 15, 2024

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                              Vietnam: New telecommunications law

                              Provisions regarding the payment of fees for registering or maintaining the use of network numbers

                              February 15, 2024

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                              Greece: Guidance on new reporting obligations for digital platform operators (DAC7)

                              Decision A.1016/2014 extends the deadline for submitting the required data or nil reporting for the year 2023.

                              February 13, 2024

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                              Philippines: Tax on e-commerce transactions

                              Regulations issued to impose a withholding tax on gross remittances made by e-marketplace operators and digital financial service providers

                              February 9, 2024

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                              Senegal: VAT on cross-border provision of digital services

                              Covered nonresidents are required to comply with the rules starting 1 April 2024

                              February 6, 2024

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                              Japan: Outline of 2024 tax reform proposals

                              The ruling governing coalition agreed to an outline of tax reform proposals for 2024.

                              February 5, 2024

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                              Japan: Additional guidance on income inclusion rule

                              The National Tax Agency released guidance in the form of Q&As on income inclusion rule

                              February 5, 2024

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                              Colombia: Modified tax Form 490 includes significant economic presence corporate income tax payments

                              Colombian tax authority (CTA) issued Resolution No. 4 modifying tax Form 490

                              February 1, 2024

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                                January 2024
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                                Tanzania: VAT and DST obligations for nonresident providers of cross-border electronic services

                                All nonresident providers of electronic services must register for VAT and DST voluntarily using a simplified registration framework

                                January 31, 2024

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                                Germany: Guidance on obligations of payment service providers, other VAT developments

                                Guidance regarding obligations of payment service providers within framework of new centralized European system

                                January 30, 2024

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                                Nigeria: Guidelines to simplify the compliance regime for goods sold through digital means postponed indefinitely

                                The guidelines were scheduled to become effective from 1 January 2024.

                                January 19, 2024

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                                Mexico: List of 201 registered foreign providers of digital services (as of 31 December 2023)

                                The tax administration published a list of foreign providers of digital services that are registered for tax purposes.

                                January 18, 2024

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                                Italy: Pillar Two global minimum tax rules implemented

                                Legislative decree n. 209 implemented the EU Minimum Tax Directive in Italy effective 1 January 2024.

                                January 18, 2024

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                                Czech Republic: Legislation introducing top-up tax, implementing EU directive on global minimum tax, now effective

                                The law introducing a top-up tax to implement the EU directive on global minimum tax became effective on 31 December 2023.

                                January 17, 2024

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                                Poland: Bill on cryptoassets; Minister of Finance activities for 2024

                                Reports about recent tax-related developments

                                January 16, 2024

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                                France: Tax-related provisions in finance law for 2024

                                Pillar Two rules and transfer pricing documentation changes

                                January 12, 2024

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                                Korea: Amendments to Pillar Two rules enacted

                                The National Assembly passed the 2023 tax reform proposal, which includes amendments to the Korean Pillar Two global minimum tax rules.

                                January 11, 2024

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                                Fourth Circuit: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

                                A Fourth Circuit case concerning Maryland’s tax on digital advertising

                                January 10, 2024

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                                India: Guidelines for withholding tax on e-commerce transactions

                                Central Board of Direct Taxes (CBDT) guidelines under section 194-O in the Income-tax Act 1961

                                January 5, 2024

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                                Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

                                Legal advice memorandum from the Office of Chief Counsel

                                January 2, 2024

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                                KPMG report: Pillar Two rules and the asset management industry

                                The rules can impose additional tax on MNE groups when the UPE is a flow-through entity.

                                January 2, 2024

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                                Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax

                                Income inclusion rule (IIR), undertaxed profits rule (UTPR), and domestic minimum top-up tax (DMTT)

                                January 2, 2024

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