Tax Controversy
KPMG TaxNewsFlash reports of tax controversy and dispute resolution developments from around the globe
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Australia: Guidance on debt deduction creation rules
The debt deduction creation rules will apply to assessments for income years starting on or after July 1, 2024.
April 1, 2025
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Notice of filing of petition for addition of polyisobutylene to Superfund list
A petition has been filed requesting that polyisobutylene be added to the list of taxable substances under section 4672(a).
April 1, 2025
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Italy: Imposition of IRAP on dividends may be inconsistent with PSD depending on nature of tax (CJEU Advocate General opinion)
Turns on whether Italian regional tax on productive activities (IRAP) is a corporation tax or tax comparable to a corporation tax
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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Germany: Final guidance on interest deduction limitation rules
Clarifications and examples regarding the application of the 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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Netherlands: Capital loss upon liquidation of subsidiary allowed (Supreme Court decision)
Losses at level of liquidated subsidiary could not be used under group relief regime after liquidation
April 1, 2025
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Latest tax developments from the United States and from KPMG member firms around the globe
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Germany: Liability for incorrect tax statements (Federal Tax Court decision); other VAT developments
Recent VAT developments in Germany
March 31, 2025
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Germany: Transfer pricing documentation requirements for extraordinary business transactions in 2025
New rules require automatic submission within 30 days of transfer pricing documentation upon notification of an audit
March 28, 2025
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Ways and Means Republicans reintroduce OECD Pillar Two reciprocity bill
“Unfair Tax Prevention Act” would increase the U.S. BEAT where foreign countries adopt Pillar Two’s UTPR
March 28, 2025
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Senate confirms Michael Faulkender as Deputy Treasury Secretary
Confirmed by a vote of 53-43
March 27, 2025
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Senate passes joint resolution overturning digital asset information reporting regulations
The resolution now goes to President Trump, who is expected to sign it.
March 27, 2025
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Announcement 2025-13: U.S. APMA program, APA statistics for 2024
26th report describing the experience, structure, and activities of the APMA program
March 27, 2025
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IRS practice unit: Section 179D energy efficient commercial buildings deduction
LB&I practice unit about section 179D energy efficient commercial buildings deduction
March 27, 2025
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White House announces 25% tariffs on automobile imports
The tariffs will take effect for automobiles on April 3, 2025, and for automobile parts, by no later than May 3, 2025.
March 27, 2025
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Cyprus: Deadlines for filing company income tax returns (TD4) for tax years 2022 and 2023
Late payments are subject to interest and monetary penalties.
March 27, 2025
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Finland: Central bank in third country exempt from income tax (Supreme Administrative Court decision)
Imposing withholding tax on dividends from Finnish listed companies constituted a prohibited restriction on the free movement of capital
March 27, 2025
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U.S. BIS adds over 80 entities to Entity List
Entities from China, Iran, Pakistan, South Africa, Taiwan, and the UAE
March 26, 2025
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Chile: Clarification regarding responsibility for payment of withheld taxes; other direct and indirect tax developments
A report summarizing recent direct and indirect tax developments
March 26, 2025
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Germany: Real estate transfer tax group exemption rule inapplicable to transfer of foreign shares (Federal Tax Court decision); other tax developments
Recent tax developments in Germany
March 26, 2025
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Saudi Arabia: E-invoicing mandatory for taxpayers with revenue above SAR 1 million
22nd group of taxpayers required to comply with the second phase of the e-invoicing system implementation
March 26, 2025
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KPMG article: How generative AI can improve transfer pricing processes
Questions and points to consider when using GenAI
March 26, 2025
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White House announces Secretary of State may impose 25% tariff on goods from any country importing Venezuelan oil
Effective April 2, 2025
March 25, 2025
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KPMG report: Accounting for indemnification arrangements associated with transferable credits
Overview of accounting for indemnification arrangements associated with the acquisition of transferable credits
March 25, 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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IRS practice units: Various partnership, foreign tax credit, and compensation issues
Eight LB&I practice units covering various partnership, foreign tax credit, and compensation issues
March 24, 2025
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Iceland: Transfer pricing adjustment and penalty upheld (Reykjavik District Court decision)
The court upheld the tax authority´s transfer pricing adjustment and 25% penalty surcharge in the country’s first transfer pricing court case.
March 24, 2025
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Federal Circuit: “Hatch-Waxman” litigation expenses not capital expenses and may be deducted in year incurred
Federal Circuit affirms Court of Federal Claims decision allowing taxpayer to deduct expenses in year incurred
March 21, 2025
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Announcement 2025-8: Competent authority arrangement under U.S.-Switzerland treaty regarding dividends received by retirement plans
CAA is operative for dividends paid on or after January 1, 2020
March 21, 2025
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Costa Rica: Consultation on selection and risk criteria for CRS compliance audits
Consultation on new criterion for objective selection criteria for CRS compliance audits
March 21, 2025
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Serbia: Law on central register of beneficial owners enacted
Introduces amendments to existing requirements for registration in central registry of beneficial owners
March 21, 2025
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Tanzania: Guidance regarding submission of beneficial owner information to registrar of companies
Local companies failing to submit information by April 15, 2025, will not be able to perform any transactions with registrar
March 21, 2025
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Australia: Impact statement on recent Full Federal Court Division 7A decision
ATO will not revise its views until appeal process finalized
March 20, 2025
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India: Rights entitlements not company shares for purposes of Ireland treaty (Tribunal decision)
Gains from transfer of rights entitlements thus not taxable in India under treaty
March 20, 2025
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U.S. OFAC amendments to Reporting, Procedures and Penalties Regulations
A final rule to amend the Reporting, Procedures and Penalties Regulations, and extend recordkeeping requirements
March 19, 2025
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Egypt: Amendments to tax procedures; tax incentives for small businesses
Amendments include penalty relief, compliance incentives, tax dispute resolution aids
March 19, 2025
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Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition
Countries and territories on EU list of non-cooperative jurisdictions, but not Poland’s list
March 19, 2025
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Poland: Re-registered entity qualifies as taxpayer starting business activities for corporate income tax purposes (Supreme Administrative Court decision)
Entity thus entitled to preferential treatment under corporate income tax rules
March 19, 2025
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UAE: Accreditation process for e-invoicing
Process may take up to 90 working days
March 19, 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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France: Retroactive application of exit tax incompatible with EU law (Supreme Administrative Court decision)
The decision is final and cannot be appealed.
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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Slovenia: Revised law project mandating e-invoicing
This project is still under evaluation.
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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India: Clarification to guidance that grandfathering provisions in tax treaties are excluded from principal purpose test
Guidance does not affect application of other treaty provisions or anti-abuse rules
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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Turkey: Updated guides on taxation of business income
Details on exemptions, computations, and compliance requirements
March 17, 2025
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Senate passes continuing resolution to fund government
Legislation includes an additional rescission of approximately $20 billion of the original approximately $80 billion in IRS funding
March 14, 2025
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Belgium: Dividend received deduction (DRD) restrictions on intra-group transfers violates EU law (CJEU judgment)
Compatibility of Belgium's DRD regime and tax consolidation system with the EU parent-subsidiary directive (PSD)
March 14, 2025
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Australia: Proposed amendments to income tax law following ATO’s alert on managed investment trust (MIT) structures
The announcement follows the ATO’s taxpayer alert, which was released on March 7, 2025.
March 14, 2025
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Belgium: Recent trends in transfer pricing audits
Overview of recent trends in transfer pricing audits in Belgium
March 14, 2025
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Germany: Updated CRS communication manual requires electronic notification for missing self-disclosures
Written notifications are no longer accepted.
March 14, 2025
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IRS provides tax relief for taxpayers affected by storms in West Virginia
Taxpayers in parts of West Virginia have until November 3, 2025, to file various federal tax returns and make payments.
March 14, 2025
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Costa Rica: Draft guidance on new requirements for taxpayers during tax audits
Aimed at enhancing tax administration efficiency through digital means
March 13, 2025
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Australia seeks exemption from U.S. tariffs on steel and aluminum, will not impose reciprocal tariffs
Government continues to work for a different outcome while discussions with Trump Administration are ongoing
March 13, 2025
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Canada introduces countermeasures in response to U.S. tariffs
Canada also requested WTO dispute consultations
March 13, 2025
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Kazakhstan: Changes to rules for monitoring cross-border transactions; additional deductions for R&D expenses
Changes to rules for monitoring cross-border transactions are effective January 27, 2025
March 13, 2025
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Mongolia: MLI effective January 1, 2025; other direct and indirect tax developments
Including tax incentives for corporate socially responsible investments
March 13, 2025
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Poland: Real estate depreciation; no VAT on free-of-charge transfers; reduction of VAT taxable amount upon lease termination; lump-sum income tax on advances (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
March 13, 2025
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House passes continuing resolution to fund government
The Senate is expected to consider the legislation this week.
March 12, 2025
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Dominica: Mutual agreement procedure (MAP) guidelines
Guidelines clarify that Dominica does not offer bilateral advance pricing agreements (APAs)
March 12, 2025
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Barbados: Monthly corporation tax prepayment requirements
Beginning in 2025, all companies are required to prepay corporation tax on a monthly basis, except for companies registered as approved small businesses.
March 12, 2025
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China: Guidance on certificate of tax residency
Various updates effective April 1, 2025
March 12, 2025
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House overturns digital asset information reporting regulations
The resolution will next be sent to the Senate, which is expected to pass it.
March 12, 2025
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Czech Republic: Denial of deductions for restoration costs upheld (Supreme Administrative Court decision)
Taxpayer failed to sufficiently prove the extent and manner of incurring the costs, including the identity of the contractor.
March 12, 2025
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EU countermeasures in response to U.S. tariffs on steel and aluminum imports
Countermeasures could apply to U.S. exports worth up to €26 billion
March 12, 2025
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India: Relaxation of conditions to carry forward losses not allowed (High Court decision)
Taxpayer sought additional time to meet production level requirements, but failed to do so even within extended period.
March 12, 2025
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Malta: Guidelines on election allowing insurance companies to pay tax on gains from adoption of IFRS 17 on installment basis
Guidelines define terms and set conditions for election
March 12, 2025
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Spain: Whether discriminatory tax treatment of nonresidents in taxing capital gains infringes EU law (CJEU referral)
Referral by European Commission due to failure to remedy alleged infringement of EU law
March 12, 2025
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Australia: Arrangements that “inappropriately access” managed investment trust (MIT) withholding regime
Taxpayer alert addresses concerns over arrangements to restructure an existing trust to inappropriately access the MIT withholding regime
March 11, 2025
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Canada: Late amendment by tax authority in transfer pricing dispute allowed (Tax Court decision)
Amendment made after deadline for competent authority relief under treat had expired
March 11, 2025
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U.S. BIS requests comments on section 232 investigations into imports of wood products and copper
Comments due by April 1, 2025
March 11, 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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Connecticut: Extended filing and payment deadline for 2024 composite income tax and passthrough entity tax returns
New forms not yet integrated into tax authority platform
March 11, 2025
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Dominican Republic: Tax credit for e-invoicing implementation
Guidance on the process for taxpayers to claim a tax credit
March 10, 2025
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Australia: Car park exempt from fringe benefits tax due to operational purpose and fee structure (Federal Court decision)
The decision challenges the ATO's interpretation of what constitutes a commercial parking station.
March 7, 2025
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Liechtenstein: Updated CRS guidance for AEOI
Revision of automatic exchange of information sheet under CRS regime
March 7, 2025
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Sweden: Proposed increase to property tax for wind turbines; deductions for fictitious tax under income tax treaty with Luxembourg
Government proposal; tax agency statement
March 7, 2025
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Philippines: Expansion of e-invoicing resumed
Previously limited to large taxpayers
March 7, 2025
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Saint Kitts and Nevis: Guidance on process to deregister from AEOI portal
Reporting financial institutions that no longer meet the FATCA and CRS reporting obligations are eligible to deregister from the AEOI portal.
March 7, 2025
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White House announces adjustments to tariffs on imports from Canada and Mexico
Aim to minimize disruption to the U.S. automotive industry
March 6, 2025
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Cameroon: Guidelines for local country-by-country declarations
Content, format, and procedures for filing local CbC declarations
March 6, 2025
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Canada and China request WTO dispute consultations over U.S. tariff measures
World Trade Organization circulated requests from Canada and China for dispute consultations with the United States
March 6, 2025
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Liechtenstein: Updated FATCA reporting technical guidance
Updated guidance reflects extension of temporary relief for foreign financial institutions regarding reporting of U.S.TINs
March 6, 2025
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Rev. Rul. 2025-7: Interest rates, tax underpayments and overpayments remain the same for second quarter 2025
Interest rates for the calendar quarter beginning April 1, 2025
March 6, 2025
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Sweden: Support services are not unique, market value must be determined based on comparables (CJEU Advocate General opinion)
Advocate General rejected tax authority’s application of revaluation rules
March 6, 2025
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Poland: No joint and several VAT liability for third parties not part of legal proceedings (CJEU judgment)
Polish VAT rules allowing joint and several VAT liability for third parties held incompatible with EU law
March 6, 2025
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Belize: Tax administration announces upcoming e-invoicing mandate
Effective date has not been announced
March 5, 2025
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Czech Republic: Taxpayer failed to prove actual amount of nondeductible indirect shareholding expenses (Supreme Administrative Court decision)
Taxpayer submitted differing and incoherent calculations
March 5, 2025
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President Trump addresses TCJA and other tax proposals in speech to Congress
Other tax proposals include exclusions of income from tips, overtime pay, and social security
March 5, 2025
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Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions
Rev. Proc. 2025-17 provides information to any individual who failed to meet the eligibility requirements of section 911(d)(1)
March 5, 2025
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Australia: Non-compliant small businesses to shift to monthly GST reporting
From April 1, 2025, non-compliant small businesses will move from quarterly to monthly GST reporting
March 5, 2025
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Australia: Termination of taxpayer’s gaming licenses did not create financial arrangement subject to TOFA rules (Federal Court decision)
Court also provided useful commentary on TOFA balance adjustment rules
March 5, 2025
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Colombia: Draft guidance modifying e-invoicing requirements
Guidance would introduce a mechanism to facilitate identification of the purchaser
March 5, 2025
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India: Payments for bareboat chartering of dredger not taxable as royalties under Belgium treaty (Tribunal decision)
Based on definition of royalties under treaty
March 5, 2025
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Notice 2025-16: Housing expense limit adjustments, foreign locations for 2025
Increased amount that a qualified individual can elect to exclude from gross income as a housing cost amount
March 5, 2025
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OECD: BEPS Action 14 MAP peer review results
Progress in making dispute resolution more effective under the BEPS package
March 5, 2025
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United States increases tariffs on Chinese imports to 20%
Changes effective March 4, 2025
March 4, 2025
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Denmark: Computational adjustments for foreign withholding tax relief were subject to extended reassessment deadline for controlled transactions (Supreme Court decision)
Adjustments are covered by section 26(5) of the Danish Tax Administration Act
March 4, 2025
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Australia: Tax authority statement regarding Federal Court decision that taxpayer entitled to interest deductions with respect to foreign related-party financing
Statement summarizes tax authority’s views on the decision
March 4, 2025
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EU updates guidance on preferential rules of origin
Includes a new section on the verification of the proof of origin
March 4, 2025
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Poland: Tax exemption limited to externally managed investment funds incompatible with EU law (CJEU judgment)
Tax exemption found incompatible with free movement of capital
March 4, 2025
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Serbia: Rulebook on arm’s length interest rates for 2025
Interest rates for all non-finance entities and a single interest rate for banks and finance leasing companies
March 4, 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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Germany: Taxpayer not entitled to apply margin-scheme taxation; other VAT developments
Recent VAT developments in Germany
March 3, 2025
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U.S. tariffs on Canada and Mexico take effect March 4; duty-free de minimis treatment allowed
Notices of implementation of executive orders imposing tariffs on Canadian and Mexican products and amendments to those orders
March 3, 2025
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United States initiates Section 232 investigation into timber and lumber imports
Investigation will assess factors such as U.S. production capacity, non-U.S. competition, and the impact of non-U.S. subsidies
March 3, 2025
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Australia: Consultation on draft legislation on 2025 tax return filing requirements
Including income tax returns, franking returns, venture capital deficit tax returns, and ancillary fund returns
February 28, 2025
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Australia: Ruling on taxation of bonuses paid to employees as part of sale transaction
Bonuses not immediately deductible but instead deductible over five years
February 28, 2025
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Ireland: Updated AEOI guidance
The Irish Revenue Commissioners issued updated AEOI guidance.
February 28, 2025
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Australia: Guide correcting “common myths” about Division 7A
ATO released a guide that "debunks common myths" about Division 7A
February 27, 2025
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Israel: Consultation on draft guidance regarding local R&D centers and IP valuations
Draft guidance on arrangements for which the tax authority may provide certainty
February 27, 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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IRS reminder: March 3 deadline for farmers and fishers who did not make estimated tax payments
Deadline applies to farmers and fishers who did not make a 2024 estimated tax payment by January 15, 2025
February 27, 2025
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House Ways and Means approves joint resolution to overturn digital asset information reporting regulations and two disaster-related tax bills; JCT descriptions
In advance of the markup, the staff of the JCT released descriptions.
February 26, 2025
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Belgium: “Fairness tax” compatible with EU law (CJEU judgment)
Belgium's "fairness tax" did not breach the freedom of establishment.
February 26, 2025
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India: Activities of Indian subsidiary did not create PE for Finish parent under Finland treaty (High Court decision)
Subsidiary was pursuing independent line of business and had no authority to bind parent
February 26, 2025
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Poland: Proposed amendments to mandatory disclosure rules (DAC6)
The government is expected to adopt the proposed amendments in the second quarter of 2025.
February 26, 2025
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O’Donnell resigns as acting IRS Commissioner; Krause to serve until nominee is confirmed
Melanie Krause will become the acting IRS Commissioner following Doug O'Donnell's retirement.
February 26, 2025
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KPMG report: Partnership related-party basis adjustment transactions of interest
Reporting requirements imposed on both taxpayers and material advisors
February 26, 2025
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USTR requests comments on proposed Section 301 actions concerning China’s maritime and shipbuilding practices
Deadline to submit comments is March 24, 2025.
February 25, 2025
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Malaysia: New deadlines for e-invoicing compliance
The deadline is either July 1, 2025, or January 1, 2026, depending on annual turnover or revenue.
February 25, 2025
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Poland: Retroactive changes to depreciation rates; application of VAT split payment mechanism; special economic zone activities; no permanent establishment without profit (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
February 25, 2025
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IRS provides tax relief for taxpayers affected by storms in Kentucky
Taxpayers in the entire state of Kentucky have until November 3, 2025, to file various federal tax returns and make payments.
February 25, 2025
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Taiwan: Updated list of low-tax jurisdictions
Effective December 27, 2024
February 25, 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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White House memorandum on U.S. tax and trade policies focuses on China
Including review of whether to suspend or terminate 1984 U.S.-China income tax treaty
February 24, 2025
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Greece: New law introduces tax measures for tips, sole proprietorships, short-term rentals, and payment deadlines
Law 5162/2024 provides tax exemption on tips up to €300 per month
February 24, 2025
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U.S. Tax Court: U.S. parent company not allowed foreign tax credits under former section 902 and section 960
Non-U.S. partnership interposed between two tiers of non-U.S. corporations made no distributions and no income inclusion at U.S. parent company level
February 24, 2025
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U.S. CBP extends Vessel Entrance and Clearance Automation Test
Extension for an additional 24 months, until February 21, 2027
February 24, 2025
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Australia: Unpaid present entitlement to income or capital of trust estate not a loan (Full Federal Court decision)
Decision may guide interpretation of similar arrangements in other contexts
February 21, 2025
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Notice 2025-15: Guidance regarding health coverage reporting required by sections 6055 and 6056
Guidance regarding alternative manner of furnishing health coverage statements under sections 6055(c)(3) and 6056(c)(3)
February 21, 2025
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Chile: Updated procedures for transfer pricing adjustments; other direct and indirect tax developments
A report summarizing recent direct and indirect tax developments
February 21, 2025
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USTR seeks public comments on foreign trade practices
Deadline for comments is March 11, 2025
February 21, 2025
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Denmark: Carbon tax refunds for captured and stored CO2 emissions
Effective January 1, 2025
February 21, 2025
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House CRA targets include digital asset information reporting regulations
Potential targets for overturning under the Congressional Review Act
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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Netherlands: Updated guidance on tax treatment of stock options
Stock options taxed when shares become tradeable rather than an exercise
February 20, 2025
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Poland: Applicability of VAT exemption; UK sales revenue determined net of UK VAT (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
February 20, 2025
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Vietnam: MCAA for exchange of CbC reports signed; amendments to transfer pricing regulations
Report on recent transfer pricing developments in Vietnam
February 20, 2025
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UK: Taxation of payments based on UK continental shelf oil production under Canada treaty (Supreme Court decision)
Payments not subject to corporation tax under treaty, but subject to “ring fence” taxation
February 20, 2025
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Austria: Notifications for certain outbound payments due February 28; other recent direct and indirect tax developments
A summary of recent direct and indirect tax developments.
February 19, 2025
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India: Reimbursements of seconded employees’ salaries not taxable in India under U.S. treaty (High Court decision)
Seconded employees were employees of Indian company
February 19, 2025
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Liechtenstein: Adoption of consultation report on CARF Act, amendments to AEOI Act
The consultation period is open until April 17, 2025.
February 19, 2025
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Lithuania: Commentary on definition of permanent establishment
Includes guidance on registration, tax periods, taxable profits, and allocated expenses
February 19, 2025
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Lithuania: Updated lists of CRS reportable and participating jurisdictions
Updated lists effective December 24, 2024
February 19, 2025
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Ukraine: Updates to scope of “controlled transactions” for transfer pricing purposes
Updated list of low-tax jurisdictions, transactions with permanent establishment in Ukraine of Austrian limited partnership
February 19, 2025
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EU: Council adopts new legislation on electronic VAT exemption certificate
The electronic VAT exemption certificate will be mandatory from June 30, 2032.
February 18, 2025
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EU: European Commission publishes work program for 2025
Key takeaways from the 2025 work program
February 18, 2025
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EU: Updated list of non-cooperative tax jurisdictions
No new jurisdictions were added to the list of non-cooperative jurisdictions.
February 18, 2025
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Saudi Arabia: Extended deadline to apply new Zakat regulations
New deadline is April 30, 2025
February 18, 2025
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Mauritius: Eligibility to claim partial exemption on interest income (Supreme Court decision)
Decision of the Supreme Court regarding partial exemption regime on interest income.
February 18, 2025
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Netherlands: Class action against interest on tax due charged for corporate income tax
The proceedings pending before the Supreme Court concern interest on tax due charged for the period January 1, 2022 through December 31, 2023.
February 18, 2025
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Netherlands: Tax return deadline for inframarginal electricity levy is April 1, 2025
Temporary legislation capping the revenue of electricity producers for the period December 1, 2022, through July 1, 2023
February 18, 2025
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Thailand: Free trade agreement with EFTA signed
European Free Trade Association (EFTA) includes Switzerland, Norway, Iceland, and Liechtenstein
February 18, 2025
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Panama: Updated tax compliance deadlines and regulatory requirements
Tax developments include a deadline extension and new regulatory obligations for resident agents and legal entities
February 17, 2025
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Australia: Updated form and instructions for thin capitalization test choice
Updated guidance regarding revocation requests
February 14, 2025
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Malaysia: Introduction of self-assessment regime for stamp duty, new stamp duty audit framework
New self-assessment regime effective January 1, 2026
February 14, 2025
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Philippines: Pre-border technical verification and cross-border electronic invoicing system
Digital and integrated systems required for all imported commodities within two years of the order's issuance
February 14, 2025
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Costa Rica: Proposed amendments to procedures for international tax information exchange
Proposed amendments include enhancing frameworks for automatic exchange of tax information
February 14, 2025
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Spain: Public country-by-country reporting obligations
Overview of public CbC reporting obligations in Spain
February 14, 2025
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UAE: Amendments to excise taxation of electronic smoking implements; guidance on correcting VAT return errors
Changes effective January 2025
February 14, 2025
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UK: Public consultation on e-invoicing
Consultation closes May 7, 2025
February 14, 2025
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Cyprus: Penalty relief for late 2022 tax filings
Tax filings must be submitted by May 31, 2025
February 13, 2025
News
Costa Rica: Deadline to implement changes in e-invoices extended
New deadline is September 1, 2025
February 13, 2025
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Costa Rica: Guidance on obligation of certain taxpayers to submit annual transfer pricing information return
Guidance includes format of return and instructions
February 13, 2025
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Rev. Proc. 2025-15: Insurance companies, unpaid loss discount factors for 2024 accident year
For use in computing discounted unpaid losses under section 846 and discounted estimated salvage recoverable under section 832
February 13, 2025
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President Trump orders examination of use of reciprocal tariffs
The “Fair and Reciprocal Plan” will examine non-reciprocal trade relationships with all U.S. trading partners.
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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Uruguay: Updated list of low or no tax jurisdictions
Updated list effective January 1, 2025
February 13, 2025
News
Austria: Determination of amount of employee monetary benefit from employer events (Finance Court decision)
General costs of employer events not treated as monetary benefits to employees
February 12, 2025
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Trump signs executive orders reconfirming standing hiring freeze for IRS, requiring OIRA review of tax regulations
Executive orders aimed at reducing size of federal government’s workforce and regulatory burdens
February 12, 2025
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House Ways and Means approves four bills aimed at improving tax administration; JCT descriptions
In advance of the markup, the staff of the JCT released descriptions of the bills and the amendments in the nature of a substitute.
February 12, 2025
News
Rev. Proc. 2025-16: Automobile depreciation deduction limits for 2025
Section 280F limitations are required to be adjusted for inflation for automobiles placed in service after 2018
February 12, 2025
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KPMG report: Observations on the final Form 4626 Instructions for CAMT
Final Instructions for 2024 Form 4626, “Alternative Minimum Tax – Corporations”
February 12, 2025
News
White House announces 25% tariffs on all steel and aluminum imports
Effective March 12, 2025
February 11, 2025
News
Australia: Instructions for reportable tax position schedule for 2025
Various updates in response to new rules and legislative changes
February 11, 2025
News
Colombia: Reporting obligations for digital platform operators implemented
Resolution 199 of 2024
February 11, 2025
News
India: Limitations on deductibility of head office expenses inapplicable under UAE treaty (Tribunal decision)
Limitations did not apply because not specifically referenced in treaty
February 11, 2025
News
Poland: Payment to achieve target profitability not subject to VAT; only one tax identification number required (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
February 11, 2025
News
Prospects for tax legislation affecting exempt organizations in the 119th Congress
Trump Administration is urging Congress to enact substantial tax reform, which could affect tax-exempt organizations
February 11, 2025
News
U.S. CBP amends notice on additional duties for Chinese products, reinstating de minimis exemptions
Changes to the HTSUS and adjustments to the de minimis exemption treatment
February 10, 2025
News
U.S. BIS issues temporary denial order for illegal transshipment of U.S.-origin goods to Russia
Temporary denial order against several individuals and companies for allegedly violating U.S. export regulations
February 10, 2025
News
Philippines: Guidance on excise tax exemption for electric vehicles, tax treatment of securitization transactions
Guidance under Revenue Regulations No. 1- 2025 and No. 2-2025
February 10, 2025
News
Kazakhstan: Amendments to VAT refund rules
Amendments effective on February 11, 2025
February 10, 2025
News
Czech Republic: Implementation of interest and royalties directive (CJEU referral)
Questions regarding whether directive permits retroactive withholding tax exemptions
February 7, 2025
News
Ireland: Updated guidance regarding controlled foreign company (CFC) rules
Incorporating changes from the Finance Act 2024
February 7, 2025
News
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
News
KPMG report: State and local tax changes affecting 2024 filing and payment obligations of entities taxed as partnerships
Summary of significant state and local tax changes affecting entities taxed as partnerships
February 6, 2025
News
OECD: Preferential tax regimes under BEPS Action 5
Latest peer review results
February 6, 2025
News
Saudi Arabia: Application of withholding tax under income tax treaties
Guidance on the application of withholding tax under income tax treaties
February 6, 2025
News
UK: HMRC transfer pricing and diverted profits tax statistics for FY 2023-2024
Statistics show HMRC continues to be very active on transfer pricing initiatives
February 6, 2025
News
UK: Payments to settle regulatory investigation deductible; claim for cross-border group relief barred (court decisions)
Summaries of recent court decisions
February 6, 2025
News
Oman: Income tax treaties signed with Cyprus, Tanzania, and Bahrain
Official texts yet to be published
February 5, 2025
News
Channel Islands: Guidance on common errors in FATCA and CRS reporting (Jersey)
Guidance addressing common errors in 2023 reporting
February 4, 2025
News
IRS practice units: Partnership liabilities, outside basis, and liquidating distributions; partial disposition of a building
Five LB&I practice units covering partnerships and deductible and capital expenditures
February 4, 2025
News
Serbia: Amendments to e-invoicing rulebook
Changes generally effective January 1, 2025
February 4, 2025
News
Saudi Arabia: Guidance on application of real estate transaction tax to “build-own-operate-transfer” contracts
Guidance relating to transactions that may be exempt from real estate transaction tax
February 4, 2025
News
Spain: New obligation to keep accounting records for products subject to manufacturing excise duties
Effective January 1, 2025
February 4, 2025
News
United States announces tariffs on Canada, Mexico, and China; 30-day postponement for Canada and Mexico
In response to concerns related to drug trafficking and illegal immigration
February 3, 2025
News
Kazakhstan: Changes to transfer pricing laws included expanded reporting and disclosure requirements
Changes became effective January 10, 2025
February 3, 2025
News
Spain: Updated guidance on common errors in information received via Form 289
Updated guidance addressing the most common errors
February 3, 2025
Tax Services
News
Bahamas: Updated FATCA / CRS reporting deadlines
Submissions and reporting of FATCA / CRS will close on February 28, 2025
January 31, 2025
News
Indonesia: Implementation of new core tax administration system
New system effective January 1, 2025
January 31, 2025
News
Poland: Eligible R&D costs, separate goods for VAT purposes, deemed income of board member (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
January 31, 2025
News
Germany: Transfer of water supply systems by municipality treated as transfer of going concern for VAT purposes; other VAT developments
Recent VAT developments in Germany
January 31, 2025
News
Senate Finance leaders release discussion draft of bipartisan legislation to improve IRS services
The legislation would make “an array of common-sense fixes” to IRS procedure and administration.
January 30, 2025
News
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
News
Kazakhstan: Pilot project for registering public procurement contracts in electronic VAT invoice system
Available through December 31, 2025
January 30, 2025
News
Kazakhstan: List of large taxpayers subject to monitoring
356 large taxpayers subject to monitoring for two years
January 30, 2025
News
IRS practice units: Foreign tax credit categorization of income and taxes, carryback and carryover, sourcing of income
Three “practice units” related to foreign tax credits
January 29, 2025
News
Hungary: Mandatory e-invoicing for energy sector postponed to July 1, 2025
Originally planned to take effect on January 1, 2025
January 29, 2025
News
Hungary: Stricter import VAT deduction requirements effective March 2025
Requires importers to file monthly VAT returns and not be classified as “risky taxpayers”
January 29, 2025
News
Jamaica: Tax settlement program waives interest, penalties, and surcharges
Principal taxes must be paid off by March 31, 2025
January 29, 2025
News
Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
January 29, 2025
News
Venezuela: Regulations regarding requirements for providers of computer systems used to issue invoices, other tax documents
Taxpayers required to use approved computer systems and have until March 20, 2025, to comply
January 29, 2025
News
India: Capital losses not reduced by grandfathered exempt capital gains under Mauritius treaty (Tribunal decision)
Capital losses not reduced by capital gains realized before April 1, 2017, and exempt under grandfathering provisions of India-Mauritius income tax treaty
January 28, 2025
News
Argentina: Reduced export duties
Decree No. 38/2025 and General Resolution 5643/2025
January 28, 2025
News
Senate confirms Scott Bessent as Treasury Secretary
U.S. Senate vote was 68-29
January 28, 2025
News
Channel Islands: Updated FATCA and CRS practical guidance (Jersey)
Updated practical guidance concerning nil reports and TINs
January 28, 2025
News
France: Updated FATCA technical guidance
Updates reflect IRS extension of relief for U.S. TIN codes for an additional three years
January 28, 2025
News
California: Property tax relief due to wildfires
Taxpayers generally must apply for reassessment within 12 months
January 28, 2025
News
KPMG report: German case law regarding transfers of functions
Some courts have held in favor of taxpayers arguing their transactions did not result in transfers of functions.
January 28, 2025
News
KPMG report: Employers providing employee assistance for victims of Los Angeles wildfires
KPMG report reviews the options for employers, and some of the advantages and disadvantages of each.
January 28, 2025
News
Colombia: Tax authority clarifies tax treatment for holding companies
Guidance on the coexistence of the corporate income tax ordinary regime and the special CHC regime for Colombian holding companies
January 27, 2025
News
Kenya: Tax amnesty program extended through June 2025
Includes periods up to December 31, 2023
January 27, 2025
News
France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
January 27, 2025
News
Korea: Transfer of shares subject to capital gains tax at arm’s length fair market value (Tax Tribunal decision)
Tax Tribunal decision
January 27, 2025
News
Senate Finance, Foreign Relations Committees introduce Taiwan double-tax relief bill
Legislation providing relief from double taxation of cross-border investment between the United States and Taiwan
January 24, 2025
News
Chile: Unemployment fund management company qualifies for benefits of U.S. income tax treaty; other direct and indirect tax developments
A report discussing recent direct and indirect tax-related topics
January 23, 2025
News
India: Grandfathering provision under tax treaty is excluded from principal purpose test
Guidance clarifies the application of the principal purpose test (PPT) in Indian tax treaties with grandfathering provisions
January 23, 2025
News
Finland: FATCA and CRS annual information returns for 2024 due January 31, 2025
The annual information returns must include up-to-date contact details in case the tax administration has any queries.
January 23, 2025
News
Poland: Deductibility of various expenses (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
January 23, 2025
News
Slovakia: Draft legislation implementing directive on tax transparency rules for cryptoasset service providers (DAC8)
Rules would become effective January 1, 2026
January 23, 2025
News
Australia: New transfer pricing guidance on inbound related-party funding for property and construction
Guidance highlights concerns and factors that attract tax authority’s attention
January 22, 2025
News
USTR determines that China’s targeting of maritime, logistics, and shipbuilding sectors is actionable under Section 301
USTR investigation concluded that China's actions burden or restrict U.S. commerce.
January 22, 2025
News
Malaysia: Transfer pricing guidelines and audit framework for 2024
Guidelines are effective from year of assessment 2023, and framework is effective from December 24, 2024.
January 22, 2025
News
Spain: Filings for special taxes due in early 2025
Certain communications and procedures for special taxes must be completed in early 2025
January 22, 2025
News
UK: Costs incurred in constructing quay wall eligible for plant and machinery allowances (First-tier Tribunal decision)
Recent court decision
January 22, 2025
News
United States: FATCA responsible officer certifications due July 1, 2025
Consequences of being non-compliant may include the revocation of an entity’s FATCA status
January 22, 2025
News
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
News
Trump signs executive order placing hiring freeze for federal civilian employees with no expiration date for IRS
Hiring freeze will remain in effect for IRS until lift determined to be in national interest
January 21, 2025
News
Daniel Werfel resigns as IRS Commissioner, Trump formally nominates William Long to replace him
The current Deputy Commissioner will serve as the Acting Commissioner until a nominee is confirmed.
January 21, 2025
News
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
News
KPMG report: Regulations regarding digital content and cloud transactions
Analysis and observations on the final and proposed regulations
January 21, 2025
News
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
News
KPMG report: Proposed regulations on additional five highest compensated employees subject to section 162(m)
The proposed regulations are proposed to apply for tax years beginning after the later of December 31, 2026, or the date of publication of the final regulations.
January 21, 2025
News
Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations
Legal advice memorandum from the Office of Chief Counsel
January 21, 2025
News
Romania: Clarifications on reporting form for public country-by-country disclosures
The Romanian Ministry of Finance issued a press release with regards to the reporting template to be used for public country-by-country disclosures.
January 21, 2025
News
Spain: Dividend withholding tax in breach of EU law (CJEU judgment)
Spain’s dividend withholding tax rules constitute an unjustified restriction on the free movement of capital.
January 21, 2025
News
Slovenia: Implementation of public country-by-country reporting
New provisions apply to financial years beginning on or after June 22, 2024.
January 21, 2025
News
KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
January 17, 2025
News
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
News
U.S. CBP and Treasury propose changes to duty and tax exemption for low-value shipments
Merchandise subject to specified trade or national security actions would be ineligible for the administrative exemption.
January 17, 2025
News
Notices of filing of petitions for addition of cyanuric acid, potassium carbonate, potassium bicarbonate, and sodium chlorite to Superfund list
Petitions have been filed by a single petitioner requesting that four substances be added to the list of taxable substances under section 4672(a)
January 17, 2025
News
South Africa: Meaning of “bulk” for royalty tax purposes (High Court decision)
“Bulk” means the condition of rock at the muck pile, and not in the beneficiated state
January 17, 2025
News
Senate Finance Ranking Member Wyden releases legislation to repeal sanctions, establish normal trade relations with Cuba
Aims to repeal major statutes that codify sanctions against Cuba
January 17, 2025
News
Spain: VAT filings due in January and February 2025
VAT-related requests, communications, and forms to be filed in January and February 2025
January 17, 2025
News
Rev. Proc. 2025-6: Procedures for certain applicable entities that made elective payment election on Form 990-T to change annual accounting period
Effective for changes in annual accounting periods of in-scope applicable entities for which first effective year begins on or after January 1, 2024
January 16, 2025
News
U.S. CBP releases interim final rule to implement provisions of the USMCA
Textile and apparel goods, automotive goods, and other customs provisions
January 16, 2025
News
Notice 2025-8: Updated elective safe harbor for domestic content bonus credit guidance amounts under sections 45, 45Y, 48, and 48E
Modification to safe harbor provided in Notice 2024-41
January 16, 2025
News
Rev. Rul. 2025-4: Guidance for states that have paid family and medical leave programs
Includes transition relief for state paid medical leave benefits paid made during calendar year 2025
January 16, 2025
News
Poland: VAT exemption for online platform assisting banking customers; VAT treatment of medical services consortium; VAT exemption for currency exchanges (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
January 16, 2025
News
UAE: VAT exemption does not apply to cryptocurrency mining
Public clarification that VAT exemption extended to activities involving virtual assets does not apply to cryptocurrency mining
January 16, 2025
News
KPMG report: Implications of Denham Capital Management LP v. Commissioner Tax Court Opinion
Partners were more akin to employees than passive investors and all the partnership allocations at issue were subject to self-employment
January 16, 2025
News
Announcement 2025-6: Pilot program to test changes to alternative dispute resolution (ADR) programs
IRS is requesting comments on the pilot changes
January 15, 2025
News
House passes Taiwan double-tax relief bill
U.S. House of Representatives today passed H.R. 33
January 15, 2025
News
Greece: Income tax treaty with Japan in force; list of non-cooperative countries for FY2023
Recent tax developments
January 15, 2025
News
U.S. Treasury targets Russian sanctions evasion schemes and designates Kyrgyzstani bank
Actions target a secret payment channel between Russia and China for sensitive exports
January 15, 2025
News
UAE: Guidance on tax groups, including transfer pricing rules applicable to groups
New guidance effective January 1, 2025
January 15, 2025
News
KPMG article: Tax issues raised by development of valuable digital IP and data assets
Including transfer pricing issues
January 15, 2025
News
Final regulations: Guidance relating to IRS Independent Office of Appeals
Final regulations provide that while Appeals resolution process is generally available to all taxpayers, there are certain exceptions.
January 14, 2025
News
U.S. DHS adds 37 China-based companies to UFLPA Entity List due to forced labor
Among entities added are a large supplier of critical minerals and large textile manufacturer
January 14, 2025
News
USTR releases report detailing approach to using trade tools to combat forced labor
Trade Strategy to Combat Forced Labor
January 14, 2025
News
USTR releases model negotiating texts
Cover note and five model texts
January 14, 2025
News
Egypt: New taxpayers required to comply with the mandate to issue electronic receipts for B2C transactions
Effective January 15, 2025, certain taxpayers must issue e-receipts for goods and services sold to end consumers.
January 14, 2025
News
Honduras: New obligation to submit financial statements with income tax returns, updated withholding tax tables applicable to salaries
A new obligation for all natural and legal persons and a new withholding tax table
January 14, 2025
News
Reporting deadlines for certain partnership “basis shifting” transactions identified as transactions of interest
Published version of the final rule provides reporting deadlines.
January 14, 2025
News
Saudi Arabia: Penalty waiver for taxes, including VAT and excise tax, extended through June 2025
Amnesty initiative that waives fines and penalties relating to corporate income tax, withholding tax, VAT, excise tax, and real estate transaction tax
January 14, 2025
News
Paraguay: Expanded list of taxpayers required to issue electronic invoices
The tax administration designated new large and medium taxpayers as issuers of electronic invoices.
January 14, 2025
News
U.S. BIS revises export controls on advanced computing integrated circuits and AI model weights
Interim final rule revises the Export Administration Regulations (EAR) to impose new controls
January 13, 2025
News
Proposed regulations: Guidance on corporate separations, incorporations, and reorganizations qualifying for nonrecognition of gain or loss
Including proposed regulations that would require multi-year tax reporting for corporate separations and related transactions
January 13, 2025
News
China: Report on advance pricing agreement (APA) program
Total of 296 APAs signed from 2025 to 2023, with 36 signed in 2023
January 13, 2025
News
India: Capital reduction through share cancellation resulted in transfer of capital asset (Supreme Court decision)
Transfer potentially created capital gain or loss in hands of shareholders
January 13, 2025
News
Final regulations: Guidance regarding certain disregarded payments and dual consolidated losses (DCLs)
Rules from proposed regulations relating to disregarded payment losses (DPLs) finalized, additional transition relief for application of DCL rules to Pillar Two rules
January 10, 2025
News
Final regulations: Certain partnership “basis shifting” transactions identified as transactions of interest
Final regulations adopt proposed regulations issued in June 2024 with certain changes in response to comments received
January 10, 2025
News
Final regulations: Micro-captive listed transactions and micro-captive transactions of interest
Final regulations identify certain micro-captive transactions as reportable transactions
January 10, 2025
News
U.S. Treasury furthers sanctions targeting Russian oil production and exports
Curb revenue used for war against Ukraine
January 10, 2025
News
Singapore: Updated FATCA FAQs and user guide
The Inland Revenue Authority of Singapore issued an updated version of the FATCA FAQs and IRAS supplementary XML user guide.
January 10, 2025
News
Proposed regulations: Guidance on catch-up contributions to retirement plans
Proposed regulations reflect statutory changes made by the “SECURE 2.0 Act of 2022”
January 10, 2025
News
Treasury and IRS release guidance on clean fuel production credit under section 45Z
Guidance includes notice of intent to propose regulations and notice providing annual emissions rate table
January 10, 2025
News
IRS provides tax relief for taxpayers affected by California wildfires
Affected taxpayers have until October 15, 2025, to file various tax returns and make tax payments.
January 10, 2025
News
JCT list of expiring federal tax provisions, 2024 – 2034
Expiring provisions listed by year
January 10, 2025
News
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
News
Final regulations: Guidance under section 2801 regarding the imposition of tax on certain gifts and bequests from covered expatriates
Apply to covered gifts and bequests received on or after January 1, 2025
January 10, 2025
News
Denmark: Taxpayer prepared adequate transfer pricing documentation and related party payments were arm’s length (Supreme Court decision)
Court rejected tax authority’s argument that taxpayer’s transfer pricing documentation could be disregarded and discretionary income adjustment imposed
January 9, 2025
News
India: No requirement to withhold tax on sales of goods to banks
Notification excludes certain banks purchasing goods from requirement for sellers to withhold tax from buyer on certain sales of goods
January 9, 2025
News
Poland: Contractual penalty for failure to provide services on time not excluded from tax-deductible costs (Supreme Administrative Court decision)
Penalty for failure to provide services on time not covered by Article 16(1)(22) of the CIT Act
January 9, 2025
News
Poland: Updated list of countries and territories applying harmful tax competition
Updated list became effective January 1, 2025
January 9, 2025
News
IRS announces extra day for taxpayers to file any returns, pay any tax due January 9
Extra day granted because of Carter remembrance day
January 8, 2025
News
National Taxpayer Advocate report to Congress identifying taxpayer problems
Administrative and legislative recommendations to address problems
January 8, 2025
News
Sri Lanka: New advance pricing agreement (APA) guide
Guide allows for unilateral, bilateral, and multilateral APAs
January 8, 2025
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News
Proposed regulations and Rev. Proc. 2025-9: Excise tax under section 5000D on designated drugs
Proposed regulations adopt rules consistent with substantive rules described in Notice 2023-52
December 31, 2024
News
Announcement 2025-5: Partial suspension by mutual agreement of income tax treaty with USSR as it relates to Belarus
Suspension is effective December 17, 2024, until December 31, 2026
December 31, 2024
News
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
News
Portugal: Relatedness determined on transaction date; improper rejection of transfer pricing method (Supreme Administrative Court decisions)
The Supreme Administrative Court issued two recent decisions relating to application of transfer pricing rules.
December 30, 2024
News
Turkey: Amended electronic invoice and document requirements for various sectors
Amendments include changes to transaction thresholds and mandatory compliance dates
December 30, 2024
News
Turkey: Clarified withholding tax requirements for payments from electronic commerce intermediaries to service providers
Requirements were amended by Law No. 7524
December 30, 2024
News
Turkey: Updated guide on mutual agreement procedures under income tax treaties
Guide was published on December 4, 2024
December 30, 2024
News
Final and proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity
Final and proposed consolidated return regulations
December 27, 2024
News
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
News
U.S. OFAC issues Russia-related general license and FAQ
Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related guidance
December 27, 2024
News
Oman ratifies income tax treaty with Ireland
Treaty is not yet in force
December 26, 2024
News
Technical correction to proposed regulations on corporate alternative minimum tax (CAMT)
Comments on the proposed regulations are still being accepted until January 16, 2025.
December 23, 2024
News
USTR initiates Section 301 investigation into China's semiconductor industry practices
Section 301 investigation into China's acts, policies, and practices related to targeting of the semiconductor industry for dominance
December 23, 2024
News
Taiwan: Guidance on income tax withholding, non-withholding tax statements, tax calculation for foreign enterprises
Guidance from the Ministry of Finance
December 23, 2024
News
Argentina-China income tax treaty entered into force
Income tax treaty entered into force on November 26, 2024
December 20, 2024
News
Chile: Application of U.S. income tax treaty to royalties on feature film; other direct and indirect tax developments
A report discussing recent direct and indirect tax-related topics
December 20, 2024
News
Cambodia: New transfer pricing regulations
New regulations include rules relating to required transfer pricing documentation
December 20, 2024
News
Final regulations: Rules for supervisory approval of penalties
Proposed regulations adopted with minor modifications
December 20, 2024
News
Proposed regulations: Updated rules contained in Circular 230 for tax professionals who can practice before IRS
The proposed regulations would incorporate new provisions that better align Circular 230 with the current practice environment.
December 20, 2024
News
IRS seeks feedback on draft Instructions for Form 6765, Credit for Increasing Research Activities
The IRS is seeking feedback on the draft instructions until June 30, 2025.
December 20, 2024
News
U.S. BIS updates export controls for changes agreed by Australia Group
Final rule amending the Export Administration Regulations (EAR)
December 20, 2024
News
Cyprus: Changes to framework of register of beneficial owners
Deadline for submitting beneficial owner information also extended to January 31, 2025
December 20, 2024
News
Italy: Guidance on new rules for fiscal representatives of non-EU companies
New rules are designed to fight fraudulent use of VAT exemption on imports under EU Directive 2006/112/EC.
December 20, 2024
News
Rev. Proc. 2024-42: Updated list of jurisdictions for exchanging deposit interest information
The IRS periodically issues guidance that updates and adds countries.
December 20, 2024
News
Rev. Rul. 2025-2: Covered compensation tables for 2025 plan year
The IRS provided tables of covered compensation under section 401(l)(5)(E) for the 2025 plan year.
December 20, 2024
News
Source of gain under section 937 from certain dispositions of stock (IRS Chief Counsel memorandum)
Memorandum addresses source of gain from certain sales of stock by U.S. citizen who becomes resident of Puerto Rico
December 19, 2024
News
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
News
Hungary: Guidance amending extra-profit taxes
Key changes in amended guidance on “extra-profit taxes”
December 19, 2024
News
Poland: Refund of income tax paid by Maltese subsidiary considered income (Supreme Administrative Court decision)
Refund of income tax paid by a Maltese subsidiary to its Polish parent company was considered income from participation in corporate profits
December 19, 2024
News
UK: Repayment of State aid and interest following CJEU annulment of European Commission decision
Regulations providing for repayment will become effective December 31, 2024
December 19, 2024
News
UK: Anti-abuse rule applied to deny “refreshed” losses, taxpayer’s claim qualified under small and medium-sized enterprise R&D regime (First-tier Tribunal decisions)
Reports on two recent decisions of the First-tier Tribunal
December 19, 2024
News
Australia: Taxpayers held promoters of scheme to exploit research and development tax incentive (Federal Court decision)
The court imposed civil penalties totaling AU$13.6 million.
December 18, 2024
News
Australia: List of specified jurisdictions for public country-by-country reporting
List includes 40 specified jurisdictions
December 18, 2024
News
Italy: Guidance on documentation required for special penalty protection for hybrid mismatches
Guidance clarifies contents, deadlines, and methodology of required documentation
December 18, 2024
News
Norway: New legislation mandates registration of beneficial owners
Starting July 31, 2025, companies and legal entities must register beneficial owners.
December 18, 2024
News
Canada: Updated guidance on forced labour and child labour reporting requirements
Guidance intended to assist organizations in preparing for the reporting deadline on May 31, 2025
December 18, 2024
News
Argentina: Deadline to pay PAIS tax extended until December 26
PAIS tax payment deadline extended to December 26, 2024
December 17, 2024
News
Georgia: Amended transfer pricing regulations
Regulations amended to refer to latest OECD Transfer Pricing Guidelines
December 17, 2024
News
Rev. Proc. 2025-8: Expanded waiver of eligibility rules to accounting method changes to comply with section 174
The revenue procedure is generally effective for Forms 3115 filed on or after December 17, 2024.
December 17, 2024
News
Final regulations: Definition of the term “coverage month” for computing premium tax credit
The final regulations apply to tax years beginning on or after January 1, 2025.
December 17, 2024
News
OECD: Exchange of information on tax rulings under BEPS Action 5
Eighth annual peer review of the implementation of BEPS Action 5 minimum standard on tax rulings
December 17, 2024
News
IRS announces tax relief for taxpayers in West Virginia affected by Post-Tropical Storm Helene
Various deadlines postponed to May 1, 2025
December 17, 2024
News
Washington State: Insurance company affiliate qualifies for insurance business B&O tax exemption (Supreme Court decision)
Affiliate qualifies for exemption on income earned from providing services to insurance company
December 17, 2024
News
Australia: Changes to country-by-country reporting exemption process
Changes effective for all exemption requests submitted after January 1, 2025
December 16, 2024
News
Colombia: Each participant in joint contract entitled to claim proportional share of withholding taxes
Rule providing managing partner solely entitled to claim withholding tax annulled
December 16, 2024
News
Netherlands: Amended guidelines on recovery of VAT on costs relating to share transactions
Amended guidelines will become effective July 1, 2025
December 16, 2024
News
United States: IRS updates FAQs on QI/WP/WT page
Provisions for 2017 WP agreement
December 16, 2024
News
KPMG report: Free trade agreement finalized between EU and Mercosur
Free trade agreement finalized after 25 years of negotiations
December 13, 2024
News
Australia: Consultation on updated draft ruling on application of “capital gains tax event K6”
Consultation on the updated draft taxation ruling closes February 14, 2025.
December 13, 2024
News
Notice 2025-2: Penalty relief for partnerships to provide complete Forms 8308 for section 751(a) exchanges
The IRS will not impose penalties for failing to furnish a completed Part IV of Form 8308 by the due date, provided that the partnership meets specific conditions.
December 13, 2024
News
India: New group of taxpayers required to report invoices within 30 days
The tax administration expanded the scope of taxpayers who must submit invoices to the portal within 30 days of issue.
December 13, 2024
News
Australia: Taxpayer alerts on early-stage investor tax offset scheme, Division 7A circumvention arrangements
Individuals who have entered into such arrangements advised to ask for a private ruling.
December 12, 2024
News
Australia: Updated guidance on public country-by-country reporting
Updates regarding public country-by-country reporting parent registration
December 12, 2024
News
Austria: Input VAT deduction of import VAT for leased machinery (Federal Finance Court decision); other recent direct and indirect tax developments
A summary of recent direct and indirect tax developments
December 12, 2024
News
IRS provides new tax penalty relief for Maui wildfire victims
Relief is separate from disaster relief announced in August 2023
December 12, 2024
News
EU: Council adopts new rules for harmonized withholding tax procedures (FASTER Directive)
The rules will become applicable as of January 1, 2030.
December 12, 2024
News
EU: European Court of Auditors report on ATAD, mandatory disclosure rules (DAC6), and tax dispute resolution directive (TDRD)
Report addresses design and implementation of ATAD, DAC6, and TDRD
December 12, 2024
News
EU: Final public country-by-country reporting forms published
Implementing regulation effective for financial years starting on or after January 1, 2025
December 12, 2024
News
Norway: Updated standard audit file for tax reporting standard
Updated standard will be mandatory for reporting periods after January 1, 2025.
December 12, 2024
News
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
News
USTR increases Section 301 tariffs for Chinese imports of tungsten products, solar wafers, and polysilicon
Tariff increases will take effect on January 1, 2025.
December 11, 2024
News
U.S. Tax Court: Taxpayer entitled to section 199 deductions
Tax Court held that taxpayer qualified for section 199 deductions, but found the taxpayer’s allocation of gross receipts and related expenses unreasonable.
December 11, 2024
News
Final and proposed regulations: Taxable income or loss and foreign currency gain or loss with respect to a QBU
Final and proposed regulations under section 987
December 10, 2024
News
Brazil: Further updates to electronic invoicing due to tax reform
Additional validation rules to be used for calculating amount of the new indirect taxes
December 10, 2024
News
U.S. BIS adds eight entities to EAR Entity List
Entities involved in activities such as supplying military components, enabling human rights violations, and developing surveillance technology
December 10, 2024
News
Czech Republic: Denial of mineral oil excise tax refund upheld (Supreme Administrative Court decision)
The Supreme Administrative Court upheld decision of Municipal Court that taxpayer failed to prove oil was used to produce heat.
December 10, 2024
News
KPMG article: OECD advance pricing agreement statistics for 2023
The statistics offer insights to businesses managing their transfer pricing risks.
December 10, 2024
News
United States: Scheduled maintenance for FATCA Registration System begins December 30
FATCA Registration System will be unavailable from December 30, 2024, at 9:30 PM ET to January 1, 2025, at 1:30 AM ET
December 10, 2024
News
Denmark: Digital bookkeeping system capable of handling electronic invoices required as of January 1, 2025
It is not yet a requirement to issue and receive electronic invoices, but digital bookkeeping systems must be able to handle such invoices.
December 9, 2024
News
Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies
December 9, 2024
News
Nigeria: Guidelines on advance pricing agreements
Guidelines on the procedures and conditions for advance pricing agreements in Nigeria
December 9, 2024
News
Spain: VAT notices due by end of year
Taxpayers must file certain notices by the end of the year to be effective on January 1, 2025.
December 9, 2024
News
KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”
The designations will cause certain contracts traded through these exchanges to be treated as section 1256 contracts.
December 9, 2024
News
Belgium: Changes to VAT compliance, refund processes, and procedural rules beginning January 1, 2025
Rules to be gradually implemented between January 2025 and 2026
December 6, 2024
News
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
News
U.S. BIS assessment on use of mature-node semiconductor chips
Findings are part of a survey to assess how companies source mature-node semiconductors
December 6, 2024
News
India: Transfer pricing rules applicable to transactions between foreign company and its Indian branch (Tribunal decision)
Rules must be applied because foreign company taxable in India only on the income of its Indian branch
December 6, 2024
News
IRS practice unit: Examining a reseller’s 263A computation
IRS Large Business and International division publicly released a “practice unit”
December 6, 2024
News
Lithuania: New country-by-country reporting notification requirements
New rules require that notifications be completed, submitted, and corrected electronically
December 6, 2024
News
Trump to nominate Scott Bessent as Treasury Secretary, Billy Long as IRS Commissioner
President-elect Donald Trump announced nominations for Treasury Secretary and IRS Commissioner
December 5, 2024
News
OECD: Updated International Compliance Assurance Programme (ICAP) FAQs (December 2024)
Revised FAQs reflect favorable developments in the ICAP program
December 5, 2024
News
Channel Islands: Guidance on further extension of temporary relief for U.S. TIN codes (Guernsey)
The U.S. tax authority (IRS) extended the relief concerning the reporting of U.S. TIN codes for an additional three years.
December 5, 2024
News
South Africa: Updated AEOI guidance
Updated reason codes in clarification document to AEOI guidance
December 5, 2024
News
Luxembourg: Remuneration received by board of directors member is not subject to VAT (court decision)
The Luxembourg District Court followed previous decision of CJEU
December 5, 2024
News
Poland: Minister of Finance issues ruling on tax exemptions for interest and royalties
Conditions for withholding tax exemptions on interest and royalties paid by Polish entities to nonresidents
December 5, 2024
News
Sweden: Winter car testing activities do not create PE, tax authority’s appeal of lower court decision denied (Supreme Administrative Court decision)
Testing activities do not constitute conduct of core business, required for finding permanent establishment
December 5, 2024
News
UK: Stamp duty land tax relief unavailable for tax avoidance transaction (Upper Tribunal decision)
The “main purpose” was the avoidance of corporate income tax.
December 5, 2024
News
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
News
KPMG article: Managing Italian transfer pricing audits
Complex transfer pricing examinations in Italy can lead to complications and risks for multinational enterprises.
December 4, 2024
News
Germany: Guidance on further extension of temporary relief for U.S. TIN codes
The U.S. tax authority (IRS) has extended the relief for U.S. TIN codes for an additional three years.
December 4, 2024
News
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
News
Singapore: CRS TIN guide issued
First edition of the common reporting standard taxpayer identification numbers guide
December 4, 2024
News
Potential implications of tariffs on China, Mexico, and Canada as announced by President-elect Trump
Additional 10% tariff on Chinese goods and 25% additional tariff on goods from Mexico and Canada
December 3, 2024
News
Australia: Treasury releases draft legislation for tax treaty with Portugal incorporating BEPS provisions
Consultation on the draft legislation will close on December 22, 2024.
December 3, 2024
News
German company agrees to pay $14.5 million for one violation of U.S. OFAC sanctions on Iran
The violation was egregious and not voluntarily disclosed.
December 3, 2024
News
Greece: Extended deadline for implementation of electronic delivery notes and digital tracking of goods shipment
First phase mandatory as of April 1, 2025, and second phase mandatory as of October 1, 2025
December 3, 2024
News
Germany: Changes to transfer pricing documentation requirements effective January 1, 2025
Changes introduced under Fourth Bureaucracy Relief Act include shorter response times and new “transaction matrix”
December 3, 2024
News
Saudi Arabia: E-invoicing requirement extended to 18th group of taxpayers from August 31, 2025
ZATCA announced the criteria for the 18th group of taxpayers required to comply with the second phase of the e-invoicing system implementation.
December 3, 2024
News
Australia: Parliament passes legislation implementing public country-by-country reporting
The legislation now awaits Royal Assent.
December 2, 2024
News
Australia: Application for stay of royalty withholding tax proceedings denied (Federal Court decision)
Stay sought while mutual agreement procedure ongoing under Australia-Ireland income tax treaty
December 2, 2024
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News
Proposed regulations: Previously taxed earnings and profits and related basis adjustments
Rules would address longstanding issues under sections 959 and 961
November 29, 2024
News
Final regulations: Recourse partnership liabilities and related party rules under section 752
Final rules adopt proposed regulations issued in December 2013
November 29, 2024
News
Bulgaria: Scope of supply of services under VAT Directive (CJEU referral)
The Administrative Court of Veliko Tarnovo referred a preliminary question to the CJEU
November 27, 2024
News
OECD: Global Forum releases 2024 AEOI peer review report
Details the monitoring and peer review processes, methodologies, and jurisdiction-specific findings
November 27, 2024
News
India: Arbitral award under business contract treated as business income under Japan treaty (Tribunal decision)
The income was thus not taxable in India absent a permanent establishment (PE) in India.
November 26, 2024
News
Germany: Further update on tax policy consequences from end of governing coalition, other tax developments
Recent tax developments in Germany
November 26, 2024
News
Notice 2024-85: Form 1099-K transition relief for calendar year 2024 and 2025 transactions
Form 1099-K threshold is $5,000 for calendar year 2024 and $2500 for calendar year 2025
November 26, 2024
News
Poland: General ruling on qualification for dividend withholding tax exemption
The ruling provides a taxpayer-favorable interpretation of existing regulations
November 26, 2024
News
Malaysia: Amendments to service tax regulations expand intra-group relief and update taxable services
Service Tax (Amendment) (No. 2) Regulations 2024
November 26, 2024
News
European Commission accepts Greece's measures to bring its tonnage tax scheme in compliance with State aid rules
European Commission accepts Greece's measures to bring its tonnage tax scheme in compliance with State aid rules
November 25, 2024
News
Final regulations: Disclosure of specified return information to Bureau of the Census for statistical purposes
Final rules adopt proposed regulations with minor changes
November 25, 2024
News
European Commission requests WTO consultations over anti-dumping measures imposed by China on imports of EU brandy
The request initiates WTO dispute settlement procedures, giving China 10 days to respond and arrange consultations.
November 25, 2024
News
Germany: New ZUGFeRD version 2.3.2; FAQs for e-invoicing mandate
Release of a new version that can be used for electronic invoice (e-invoice) exchange announced
November 25, 2024
News
India: Taxpayer entitled to claim business losses from commercial transactions made in good faith (High Court decision)
Tax authority cannot question commercial decisions made in good faith in the absence of substantive evidence of malpractice
November 25, 2024
News
Sweden: Administrative courts have jurisdiction to review claims for corresponding adjustment under income tax treaty (Supreme Administrative Court decision)
Corresponding adjustment is an important legal remedy for taxpayers potentially subject to double taxation
November 25, 2024
News
Announcement 2024-38: Updates on second remedial amendment cycle for section 403(b) pre-approved plans
The IRS intends to issue opinion letters for section 403(b) pre-approved plans that were updated for changes.
November 22, 2024
News
Trinidad and Tobago: Tax amnesty proposal in Finance Bill 2024
Waiver of penalties and interest for various taxes
November 22, 2024
News
Hong Kong: Upfront payment, but not necessarily ongoing royalties, under trademark sub-licensing arrangement held Hong Kong-sourced (Court of Appeal decision)
Lower court erred in law by determining all royalty income as Hong Kong-sourced
November 22, 2024
News
U.S. Treasury sanctions Russian banks and expands measures against Russian financial entities
Sanctions to limit Russia's financial access amid Ukraine conflict
November 21, 2024
News
IRS provides tax relief to taxpayers in the Crow Tribe of Montana affected by severe storms and straight-line winds
Various deadlines postponed to February 3, 2025
November 21, 2024
News
Chile: Tax treatment of transfer of invoices to U.S. resident company; other direct and indirect tax developments
A report discussing recent direct and indirect tax-related topics.
November 21, 2024
News
KPMG article: United States-Chile treaty builds tax certainty for MNEs with MAPs and APAs
Mutual agreement procedures and advance pricing agreements to mitigate double taxation
November 21, 2024
News
FBAR filings: Extended deadline is April 15, 2026, for individuals with signature authority
For all other U.S. individuals with an FBAR filing obligation, the filing due date remains April 15, 2025.
November 20, 2024
News
Barbados: Filing extension for country-by-country notifications; other tax developments
Recent developments also concern economic substance exchange jurisdictions and land tax adjustments
November 20, 2024
News
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
News
Costa Rica: New technical provisions for e-invoices
New provisions will come into effect on June 1, 2025
November 20, 2024
News
Italy: Beneficial ownership of dividend income based on parent-subsidiary directive (Supreme Court decision)
A Supreme Court decision on beneficial ownership in the context of divided payments.
November 20, 2024
News
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
News
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
News
IRS practice unit: Land developers and subcontractors—proper method of accounting
IRS Large Business and International division publicly released a “practice unit”
November 20, 2024
News
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
News
Dominican Republic: Tax authority clarifies rules on e-invoicing system
Mandates electronic billing for registered taxpayers
November 19, 2024
News
Ireland: Updated FATCA and AEOI guidance
Revisions on taxpayer identification numbers, filing guidelines, and AEOI compliance for financial account holders
November 19, 2024
News
India: Compliance campaign for disclosure of foreign assets and income
The campaign aims to guide taxpayers who have high-value foreign assets that may not have been fully disclosed in their income tax return.
November 19, 2024
News
India: Treaty exemption available to foreign airline company in respect of code sharing arrangement (Tribunal decision)
The tribunal reiterated that to qualify for exemption under Article 8 of the treaty, it is not necessary that the taxpayer itself operates the ships or aircraft.
November 19, 2024
News
UK: Exit tax must conform with EU freedom of establishment principle (Upper Tribunal decision)
The Upper Tribunal issued a decision in a case regarding tax charges on trustees and a company ceasing UK residency.
November 19, 2024
News
U.S. Treasury to allocate $10 billion in New Markets Tax Credit (NMTC) authority for 2024 and 2025
Encourages private sector investment in distressed communities
November 19, 2024
News
OECD: Mutual agreement procedure (MAP) and advance pricing agreement (APA) statistics for 2023
Decrease in global MAP inventories with more cases resolved and an increase in global APA inventories
November 18, 2024
News
U.S. Tax Court: IRS does not have statutory authority to assess penalties for willful failure to file Form 5471
U.S. Tax Court reaffirmed its original decision
November 18, 2024
News
Rev. Rul. 2024-25: Interest rates, tax underpayments and overpayments decrease for first quarter 2025
Interest rates for the calendar quarter beginning January 1, 2025
November 18, 2024
News
Malaysia: Framework for voluntary disclosure program
Comprehensive guidance on implementation of the compliance verification audit programme (AViP)
November 18, 2024
News
Australia: ATO extends filing deadline for country-by-country reporting entities
The ATO has granted a filing deferral through January 31, 2025.
November 15, 2024
News
Australia: Treasury opens consultation on legislation for enhanced ownership disclosure of listed entities
The consultation period closes on December 13, 2024.
November 15, 2024
News
Senate confirms final Biden nominee to be U.S. Tax Court judge
The Senate confirmed Cathy Fung to be a U.S. Tax Court judge.
November 14, 2024
News
U.S. life insurance company agrees to pay $178,000 for violations of sanctions on Iran
Apparent violations of Iranian Transactions and Sanctions Regulations
November 14, 2024
News
Slovakia: Tax collection and reporting guidelines in Financial Transactions Tax Act
The Financial Transactions Tax Act becomes effective on January 1, 2025.
November 13, 2024
News
Slovakia: Transfer pricing for manufacturing companies (court decisions)
Insights into how a taxpayer's functions and risks within a group are evaluated
November 13, 2024
News
IRS announces tax relief for taxpayers affected by storms and flooding in Chaves County, New Mexico
Various deadlines postponed to May 1, 2025
November 13, 2024
News
IRS provides tax relief for taxpayers in Cheyenne River Sioux Tribe in South Dakota affected by storms
Various deadlines postponed to February 3, 2025
November 13, 2024
News
Armenia: Agreement on automatic exchange of country-by-country reports
Enables the automatic exchange of key financial information from multinational enterprises
November 12, 2024
News
Bahrain: New income tax treaty with Guernsey; amendments to treaty with Czech Republic
Tax treaty developments
November 12, 2024
News
Cambodia: Guidance on tax relief and exemptions
Various guidance related to amendments to tax declarations, the real estate sector, stamp duty, and tax on salary
November 12, 2024
News
Deductibility of FDIC special assessments not limited under section 162(r)
IRS Chief Counsel memorandum
November 12, 2024
News
IRS announces tax relief for taxpayers in Saint Regis Mohawk Tribe in New York affected by storms and flooding
Various deadlines postponed to February 3, 2025
November 12, 2024
News
EU: Expansion of centralised clearance for import (CCI) system
The European Commission announced that Italy has joined the Centralised Clearance for Import system.
November 12, 2024
News
Montenegro: Multilateral agreement on exchange of country-by-country reports
MNE groups with consolidated revenues exceeding €750 million must file reports within 12 months after fiscal year-end
November 12, 2024
News
Costa Rica: Electronic invoicing regulations
Adjustments related to electronic invoicing obligations
November 12, 2024
News
UAE: Tax guide on corporate tax returns includes transfer pricing thresholds and procedures
A tax guide on corporate tax returns detailing the contents and procedures for filing.
November 12, 2024
News
El Salvador: Guidance to identify low or no taxation jurisdictions
The tax administration published a guide to help taxpayers identify low or no taxation jurisdictions.
November 12, 2024
News
South Africa: Conduit principle does not apply when capital gains are realized by trust
Constitutional Court judgment
November 12, 2024
News
Germany: Tax policy consequences from end of governing coalition
Passage of certain bills will require opposition support, which remains uncertain
November 11, 2024
News
KPMG article: IRS’s personal use of business aircraft campaign
IRS plans to begin auditing the personal use of business aircraft with its business aircraft campaign
November 11, 2024
News
Costa Rica: Automatic exchange of information for sellers on digital platforms
Digital platform operators must implement the provisions and due diligence procedures starting January 1, 2025.
November 8, 2024
News
Netherlands: Time to restructure to a "repurchase fund" extended for one year
Investments funds would have an additional year to restructure to a “repurchase fund” in order to maintain their transparent tax status
November 8, 2024
News
Netherlands: Withholding tax on dividends received by UK company potentially impermissible under EU law (CJEU judgment)
Different treatment in the Netherlands of resident and nonresident companies would constitute an unjustified restriction of the EU free movement of capital.
November 8, 2024
News
Spain: Special tax regime of the Balearic Islands; relief for taxpayers affected by flooding
Annual approval for special tax regime of the Balearic Islands and tax relief measures for taxpayers affected by DANA
November 8, 2024
News
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
News
U.S. BIS renews temporary denial of export privileges of Russian airline for one year
Based on evidence of repeated and ongoing violations of the Export Administration Regulations (EAR)
November 7, 2024
News
Panama: Tax amnesty for payment of national taxes
Tax amnesty period until December 31, 2024, for payment of interests and penalties accrued
November 7, 2024
News
Extension of certain timeframes for employee benefit plans and participants affected by Hurricane Helene, Tropical Storm Helene, or Hurricane Milton
Extension generally suspends until May 1, 2025, the tolling of various periods and dates under ERISA and the Code applicable to employee benefit plans and their participants
November 7, 2024
News
Colombia: Obligation to generate electronic payroll payment support document for payments in kind
Clarification of obligation to generate electronic payroll payment support document
November 7, 2024
News
Spain: Guidance on required specifications for electronic invoicing systems
Required technical, functional, and content specifications are provided
November 7, 2024
News
Poland: Authority of head of tax office, English version of tax treaties controls, deduction for unduly paid VAT, taxation of employer-paid insurance premiums
Summaries of recent Supreme Administrative Court decisions
November 7, 2024
News
IRS grants tax relief for taxpayers in Havasupai Tribe in Arizona affected by flooding
Deadlines extended to February 3, 2025
November 7, 2024
News
Colombia: E-invoice requirements for tax deductions in credit operations
The National Tax and Customs Directorate clarified requirements for e-invoices as support for costs, deductions, and deductible taxes in credit operations.
November 6, 2024
News
Croatia: Establishment of new company to maintain benefit of VAT exemption scheme for small enterprises constitutes abusive practice
Court of Justice of the European Union (CJEU) judgment
November 6, 2024
News
India: Nonrefundable advance maintenance fees taxable in year of receipt
Madras High Court decision
November 6, 2024
News
Kenya: Supreme Court holds Finance Act, 2023 constitutional, overturns Court of Appeal
The Supreme Court overturned a previous decision of the Court of Appeal that the entire Finance Act was unconstitutional.
November 6, 2024
News
UAE: Corporate tax guide on tax residency and tax residency certificate
A comprehensive corporate tax guide
November 5, 2024
News
KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations
The Tax Court applied the strict construction rule to decide in the taxpayer’s favor.
November 5, 2024
News
Oman signs tax treaties to avoid double taxation with Luxembourg and Estonia
Aim to eliminate double taxation on income and prevent tax evasion
November 4, 2024
News
Chile: Amendments to transfer pricing rules
Advance pricing agreements (APAs), definitions and specifications of concepts, and self-adjustments
November 4, 2024
News
U.S. DHS adds China-based textile companies to Uyghur Forced Labor Prevention Act (UFLPA) Entity List
CBP will enforce a rebuttable presumption that goods are prohibited from entering the United States.
November 4, 2024
News
Australia: ATO's 2022-2023 corporate tax transparency report
ATO also released tax and corporate Australia report, which includes the ATO’s approach to compliance of large corporates
November 1, 2024
News
Germany: Annual Tax Act 2024 would postpone new rules on withholding tax payment and reporting
Proposal would postpone the rules until 2027 (originally scheduled for 2025)
November 1, 2024
News
Latvia: Implementation of mandatory e-invoicing from January 1, 2026
Businesses registered in Latvia must issue electronic structured invoices
November 1, 2024
News
Cyprus: Extended deadline for filing 2023 individual tax returns (TD1)
Extended deadline is November 30, 2024
October 31, 2024
News
U.S. Tax Court: Loss under section 1256(c) on foreign currency option transaction disallowed under section 165(c) for lack of profit motive
Tax Court agreed with IRS that the taxpayers did not establish any profit motive for entering into the foreign currency option transactions
October 31, 2024
News
South Africa: Proposed changes to foreign exchange loss carryforward rule for non-trading companies
Non-trading companies would be allowed to carry forward aggregate foreign exchange losses
October 31, 2024
News
Cyprus: Extended deadlines for submitting 2022 and 2023 tax returns for taxpayers obligated to submit table of summarized information
New deadlines are February 28, 2025, and November 30, 2025, respectively
October 30, 2024
News
Spain: Characterization of projects by Ministry of Science and Innovation are binding on tax authority (Supreme Court decisions)
Determining whether expenses qualify for the technological innovation deduction under the corporate income tax law
October 30, 2024
News
U.S. BIS amends Export Administration Regulations (EAR) by adding to and modifying Entity List
Entities located in China, India, Malaysia, Russia, Singapore, and Turkey
October 30, 2024
News
Hungary: Mandatory e-invoicing for energy sector beginning January 1, 2025
Applicable to supplies of electricity and natural gas
October 30, 2024
News
U.S. Treasury sanctions third-country intermediaries and Russian producers supporting Russia’s military
Sanctions target illicit procurement networks and financial facilitators, which play key roles in sanctions evasion
October 30, 2024
News
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
News
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
News
EU imposes duties on imports of battery electric vehicles from China for five years
Investigation found that Chinese BEVs benefit from unfair subsidies
October 30, 2024
News
UAE: New guidance on tax residence and Tax Residency Certificate application procedures
Criteria for obtaining a Tax Residency Certificate
October 30, 2024
News
IRS practice unit: Section 250 deduction—foreign-derived intangible income (FDII)
Updated to remove references to resources that are no longer available
October 30, 2024
News
Hong Kong: Management fees paid to BVI affiliate not deductible
Court of First Instance decision
October 29, 2024
News
U.S. Treasury announces the beginning of negotiation of a tax agreement with Taiwan
United States and Taiwan will begin negotiations on a comprehensive agreement to address double taxation issues.
October 29, 2024
News
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
News
Fifth Circuit: Accountable care organization not entitled to tax exemption under section 501(c)(4); Tax Court affirmed
The ACO's activities primarily benefitted its commercial payor and healthcare provider participants rather than the public, thus disqualifying it from the exemption.
October 28, 2024
News
Notice 2024-78: Extension of temporary relief for foreign financial institutions required to report U.S. TINs
Notice 2024-78 extends the temporary relief provided in Notice 2023-11
October 28, 2024
News
Luxembourg: New online procedures for filing fund subscription tax returns
Two-year transition period, running until August 2026, will allow for both the old and new filing systems to operate in parallel.
October 28, 2024
News
Bahrain: Amendments to rules on permissible commercial activities for foreign owned companies
Amendments to certain provisions in relation to commercial activities that foreign owned companies can carry out in Bahrain.
October 28, 2024
News
Netherlands: Exemption scheme for participations falling below 5% threshold applies to covered call options (Supreme Court decision)
Aim of the participation exemption is to prevent the same profit being taxed twice in participation relationships, which applies in context of options
October 28, 2024
News
UAE: Implementation of mandatory e-invoicing from July 2026
The implementation plan will occur in three stages.
October 28, 2024
News
Argentina: Creation of new federal collection agency (ARCA)
No changes in the tax compliance process have been announced.
October 25, 2024
News
Cyprus: Deadline for 2023 individual income tax returns is October 31, 2024
Individuals with gross total income exceeding €19,500 in 2023 are required to submit 2023 returns
October 25, 2024
News
Argentina: Income tax treaty with China ratified
The treaty will become effective once Argentina completes its international approval process.
October 25, 2024
News
IRS provides tax relief to taxpayers affected by floods in Juneau, Alaska
Deadlines extended to May 1, 2025
October 25, 2024
News
Cambodia: Tax, accounting, labor, and regulatory compliance reminders for 2024-2025
Deadlines for tax compliance obligations in Cambodia for the first six months of 2025
October 25, 2024
News
Finland: Luxembourg SCS fund comparable under EU law to Finnish contractual-based special investment fund (Administrative Court decision)
Administrative Court held that a Luxembourg SCS fund resembled under EU law a Finnish tax-exempt contractual-based special investment fund that is a corporation for Finnish tax purposes
October 25, 2024
News
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
News
KPMG report: New XML schemas for cryptoasset reporting framework (CARF) and CRS amendments
Interaction with IRS Draft Form 1099-DA, Digital Asset Proceeds from Broker Transactions
October 25, 2024
News
Final regulations: Guidance on advanced manufacturing production credit under section 45X
The final regulations retain the same basic structure as proposed regulations issued in December 2023, with certain revisions.
October 24, 2024
News
Proposed regulations and Rev. Proc. 2024-31: Guidance on energy efficient home improvement credit under section 25C
General guidance on the section 25C credit, including what property qualifies and rules for manufacturers to register to be qualified manufacturers
October 24, 2024
News
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
News
Mexico: New obligations for crowdfunding platforms to withhold income tax and VAT
Rules became effective on October 12, 2024
October 24, 2024
News
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
News
Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023
Exception from filing Form 4626 for tax year 2023
October 23, 2024
News
Korea: Royalties for use of unregistered patents subject to tax under U.S. treaty (Tax Tribunal decision)
Royalties for the use of patents in Korea are considered domestic-source income, regardless of whether the patents are registered domestically or not.
October 23, 2024
News
Norway: Swedish convertible bonds classified as derivative covered by exemption method (Tax Appeals Board decision)
Tax Appeal Board ruled that the bonds were entitled to tax-free treatment under the exemption method of Tax Act 2-38.
October 23, 2024
News
United States: IRS issuing manual IDES notifications through October 31
Delayed distribution due to recent hurricanes
October 23, 2024
News
KPMG article: Potential effects of artificial intelligence on transfer pricing
An article that discusses the potential effects of artificial intelligence on transfer pricing and transfer pricing audits
October 22, 2024
News
Final regulations: Advanced manufacturing investment credit rules under sections 48D and 50
The final regulations adopt with certain modifications proposed regulations issued in March 2023.
October 22, 2024
News
Bolivia: “Twelfth group of taxpayers” to implement online billing modality
Guidance providing that certain taxpayers must adapt and implement their computer billing systems
October 22, 2024
News
France: Update on introduction of mandatory e-invoicing
Implementation timetable confirmed but scope of public portal limited
October 22, 2024
News
Singapore: Updated guidance on FATCA and CRS return
A new function in the “View CRS/FATCA Return Status” digital service on myTax Portal.
October 22, 2024
News
Cambodia: Guidance covering fiscal obligations for real estate leases, cessation of business, tax relief for airlines
Guidance from the GDT concerning implementation of fiscal obligations for real estate leases, procedures for business cessation, and tax relief measures for airline companies
October 22, 2024
News
U.S. BIS amends Export Administration Regulations (EAR) by revising entity list
BIS adds 26 entries under destinations of China, Egypt, Pakistan, and UAE
October 21, 2024
News
KPMG reports: California (bad debt deductions for sales and use tax purposes); Ohio (debit authorization services not subject to sales tax); Washington State (B&O apportionable services reconciliation)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 21, 2024
News
Notice 2024-74: Additional guidance on safe harbors for sustainable aviation fuel credit
Guidance applies as of October 18, 2024.
October 18, 2024
News
Final regulations: Withholding under sections 3405(a) and (b) on certain payments and distributions from retirement plans
The final regulations adopt proposed regulations issued in May 2019 with no substantive modifications except a changed applicability date.
October 18, 2024
News
Italy: Import VAT is considered customs duty
Legislative Decree no. 141/2024 equates import VAT with customs duties, including them both in the concept of border duties.
October 18, 2024
News
India: Long-term capital gains rate applicable to gains from depreciable assets held for more than 36 months
A special bench of the Income Tax Appellate Tribunal decision.
October 18, 2024
News
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
News
Notices related to treatment of amounts paid for contraceptives under health savings accounts and high deductible health plans
Expenditures for breast cancer screenings, glucose monitors, and certain insulin products also addressed
October 17, 2024
News
France: Announcement on e-invoice validation services
The requirement for French companies to issue and receive e-invoices will apply from September 1, 2026.
October 17, 2024
News
Vietnam-based beverage company agrees to pay $860,000 for violations of U.S. sanctions on North Korea
Civil liability for 43 apparent violations of the North Korea Sanctions Regulations
October 17, 2024
News
Poland: Character of profits of converted sole proprietorship; taxation of prizes granted to athletes; deductibility of expenses incurred by parent in support of subsidiary
Summaries of recent Supreme Administrative Court decisions
October 17, 2024
News
United States: IRS updates “public key” for FATCA filing
After November 1 at 9:00 AM EDT, the new IRS public key will need to be downloaded from IDES to file FATCA reports.
October 17, 2024
News
Mexico: Modifications to general foreign trade rules affecting IMMEX operations and VAT certifications
The modifications are effective as of October 15, 2024.
October 16, 2024
News
OECD: BEPS Actions 5 and 14 peer reviews
Second round of BEPS Action 5 peer reviews, first two batches of BEPS Action 14 peer reviews under simplified review process
October 16, 2024
News
Delaware: Changes to unclaimed property law
Many immediate and some retroactive changes
October 16, 2024
News
Saudi Arabia: Updated real estate transaction tax law
The Zakat, Tax, and Customs Authority (ZATCA) will be issuing the implementing regulations.
October 16, 2024
News
Germany: Guidelines for complying with first phase of e-invoicing mandate
The e-invoicing mandate will be gradually introduced from January 1, 2025.
October 16, 2024
News
Italy: Public country-by-country reporting implemented
The new provisions apply to financial years beginning on or after June 22, 2024.
October 16, 2024
News
Notice 2024-77: Guidance under sections 414(aa) and 402(c)(12) regarding correction of inadvertent benefit overpayments
Comments on the guidance are due by December 16, 2024.
October 15, 2024
News
Australia: Guidance on compliance approach to restructuring transactions in response to new thin capitalization rules
The draft guidance describes a series of low-risk and high-risk factors and a four-color-coded risk-assessment framework.
October 15, 2024
News
KPMG reports: South Dakota (use tax on construction equipment); Virginia (disregarded entity not subject to BPOL tax); multistate (tax-related ballot measures, manufacturing sales and use tax exemption rulings)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 15, 2024
News
IRS provides tax relief for taxpayers in Florida affected by Hurricane Milton
Tax relief until May 1, 2025, for individuals and businesses in Florida affected by Hurricane Milton
October 11, 2024
News
IRS announces dyed diesel penalty relief in Florida due to Hurricane Milton
The relief begins on October 9, 2024, and will remain in effect through October 30, 2024.
October 11, 2024
News
Australia: Legislation implementing UK to Trans-Pacific Partnership passed by Parliament
The legislation provides a “free” rate of customs duty for originating goods of the United Kingdom.
October 11, 2024
News
India: Amendments to GST rules including amnesty scheme
Introduces procedures for allowing benefits under the amnesty scheme from the Finance Act 2024
October 11, 2024
News
Uganda: Required audited financial statements for high turnover taxpayers
High turnover taxpayers with income year ended June 30, 2024, are required to submit final income tax return with audited financial statements by December 31, 2024.
October 11, 2024
News
Channel Islands: Reopening of AEOI portal for FATCA and CRS reporting (Jersey)
Financial institutions can now access the portal to submit CRS and FATCA data for all reporting periods.
October 10, 2024
News
Uruguay: AEOI portal available for submission of CRS reports
AEOI portal will be available for the submission of CRS reports from October 3, 2024, until November 30, 2024
October 10, 2024
News
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
News
Serbia: Electronic recording of input VAT not required for September 2024 tax period
The electronic recording of input VAT will begin for tax periods beginning on October 1, 2024.
October 10, 2024
News
India: Guidelines for applications to excuse delay in claiming refunds
Guidelines for taxpayers belatedly seeking refunds and carry-forward of loss
October 9, 2024
News
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
News
EU: Updated list of non-cooperative tax jurisdictions
EU blacklist now consists of 11 jurisdictions
October 9, 2024
News
U.S. BIS guidance for financial institutions on best practices to comply with Export Administration Regulations
Background information and recommendations to minimize the likelihood of EAR violations
October 9, 2024
News
Poland: Whether deductibility of VAT may be conditioned on receiving invoice (CJEU referral)
Referral to CJEU regarding compatibility of Polish VAT law with EU VAT directive
October 9, 2024
News
Hong Kong: Sourcing of profits from container trading and leasing (court decision)
Determinative factor is where taxpayer’s operations were carried out
October 8, 2024
News
South Africa-Kuwait protocol ratified by Kuwait
Protocol would eliminate exemption from South Africa’s 20% dividends tax
October 8, 2024
News
Netherlands: Interest deduction limitation anti-profit shifting rule permissible under EU law (CJEU judgment)
Rule is justified as a means of combating tax fraud and evasion
October 8, 2024
News
KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America
PPT provisions make testing availability of treaty benefits for holding companies more complex
October 8, 2024
News
Nigeria: Tax authority has discretion to determine percentage of tax on turnover of foreign companies (Federal High Court decision)
Justification of a particular percentage is not required
October 8, 2024
News
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
News
Final regulations: Certain syndicated conservation easement transactions identified as listed transactions
The final regulations adopt proposed regulations published in December 2022 with certain revisions.
October 7, 2024
News
Proposed regulations: Federal tax classification of entities wholly owned by Indian Tribal governments
Entities wholly owned by Indian Tribal governments generally would not recognized as separate entities
October 7, 2024
News
India: Procedural disputes within revived reassessment proceedings (Supreme Court decision)
Supreme Court resolves certain procedural disputes raised in revived reassessment proceedings.
October 7, 2024
News
OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
October 7, 2024
News
KPMG reports: California (sales tax agreement reports); Nevada (voluntary disclosure agreement program); New York (sales tax on electronic currency trading, web-based document processing)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 7, 2024
News
KPMG report: Analysis and observations on the proposed CAMT regulations
A report that summarizes a number of key issues from the proposed regulations and provides observations.
October 4, 2024
News
Australia: First annual R&D tax incentive transparency report
Information on R&D expenditure incurred by 11,545 companies in the 2021-22 income year
October 4, 2024
News
Australia: Supplementary annual GST return for certain large taxpayers
New return will be introduced for the 2024-2025 financial year for large taxpayers that have had a GST assurance review
October 4, 2024
News
IRS Priority Guidance Plan for 2024-2025
The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.
October 4, 2024
News
United States: IRS issues list of qualified intermediary (QI) entities and branches
QIs need to review the list and update any inaccurate information.
October 4, 2024
News
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
News
Peru: Amended deadlines for recording invoices, tax authority allowed to generate purchase register
Peru’s tax authority will propose a purchase register including all electronic invoices issued to taxpayers.
October 3, 2024
News
IRS provides tax relief for taxpayers in parts of Washington State affected by wildfires
Affected taxpayers have until February 3, 2025, to file various tax returns and make tax payments.
October 3, 2024
News
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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IRS requests comments on draft Form 7217, Partners Report of Property Distributed by a Partnership
The purpose of Form 7217 is to report all distribution of property that a partner receives from a partnership.
September 30, 2024
News
Cyprus: Deadline for confirmation of ultimate beneficial owner’s information is December 31, 2024
Certain companies must log into the register of ultimate beneficial owners between October 1, 2024 and December 31, 2024, to confirm the information of their ultimate beneficial owners
September 30, 2024
News
Chile: Tax compliance bill approved by Congress includes income tax, VAT, and transfer pricing measures
The Tax Compliance Bill, which includes a number of tax measures, was approved by Congress.
September 30, 2024
News
U.S. Treasury release: No change to list of countries cooperating with international boycott
No new countries are added, and no countries are removed from the prior list.
September 30, 2024
News
KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Japan
KPMG survey regarding how local tax authorities are approaching the control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks
September 30, 2024
News
KPMG article: Worldwide trends in transfer pricing
Case studies address common transfer pricing issues in several representative jurisdictions
September 30, 2024
News
KPMG reports: California (manufacturing equipment tax credit vetoed); Massachusetts (tax amnesty); Oregon (sales factor treatment of repatriation income); Washington State (taxable digital automated services)
Recent state and local tax developments
September 30, 2024
News
Saudi Arabia: E-invoicing requirement extended to 16th group of taxpayers from April 1, 2025
ZATCA announced the criteria for the 16th group of taxpayers required to comply with the second phase of the e-invoicing system implementation.
September 27, 2024
News
Senate confirms two U.S. Tax Court judges, one nominee remains
The Senate confirmed Jeffrey S. Arbeit and Benjamin A. Guider III to be U.S. Tax Court judges.
September 27, 2024
News
Mexico: Temporary restriction of digital seal certificates for issuance of digital tax receipts
The tax authorities may temporarily restrict the use of digital seal certificates for the issuance of digital tax receipts.
September 27, 2024
News
Mauritius-Bangladesh income tax treaty protocol signed
The protocol will enter into force once the ratification procedures are completed in Mauritius.
September 27, 2024
News
Mauritius: Renewed tax amnesty scheme under Finance Act 2024
Income tax, VAT, and gambling tax
September 27, 2024
News
Rev. Rul. 2024-22: Bourse de Montreal held “qualified board or exchange”
The revenue ruling is effective for Bourse de Montréal contracts entered into on or after November 1, 2024.
September 26, 2024
News
IRS announces new process for third-party payers to resolve incorrect employee retention credit claims
Third-party payers must submit a supplemental claim by November 22, 2024.
September 26, 2024
News
Cyprus: Additional FAQs on new transfer pricing rules
Aims to clarify certain provisions of the new transfer pricing rules
September 26, 2024
News
Philippines: Guidelines for tax refunds and credits
Mandatory requirements for processing tax credit certificates or cash refunds for erroneously or illegally collected taxes
September 26, 2024
News
United States: IRS announces manual IDES confirmations will be sent by October 15
Additional updates on IRS public key and configuring SFTP connection
September 26, 2024
News
United States extends suspension of Cyprus as “proscribed destination” for defense articles
Continues the policy initiated in October 2022 that originally lifted the arms embargo to Cyprus
September 26, 2024
News
Korea: Sales volume must be considered in determining comparability of transactions for transfer pricing purposes (Administrative Court decision)
Allegedly comparable transactions relied on by the tax authority were not, in fact, comparable
September 25, 2024
News
Australia: Approved form for thin capitalisation test choice
The Australian Taxation Office released its approved form that certain taxpayers may use to make a thin capitalisation test choice for an income year.
September 25, 2024
News
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
News
Rev. Proc. 2024-38: Guidance on income requirements for residential rental projects financed with exempt bonds and low-income housing projects
Guidance on the effect on the income requirements under section 142(d) and section 42 of the alternative income eligibility requirements
September 25, 2024
News
Costa Rica: New ultimate beneficial owner filing obligations
Various legal entities and figures, previously exempt, are now required to register and declare their ultimate beneficiary owners.
September 25, 2024
News
Peru: Changes to APA rules and introduction of new valuation methods
Changes to the transfer pricing regime effective January 1, 2025
September 25, 2024
News
Botswana: Extended filing deadlines for annual withholding and individual income tax returns
Individuals are required to file unless they earned less than P480,000 from a single employer .
September 25, 2024
News
Bahamas: Updated FATCA / CRS reporting deadlines
The Bahamas Competent Authority issued an update related to the FATCA and CRS deadlines.
September 24, 2024
News
Czech Republic: Direct and indirect tax relief in response to widespread flooding
The government issued several notices offering tax payment deferment, penalty waivers, and other tax relief.
September 24, 2024
News
Senate confirms U.S. Tax Court judge, three nominees remain
Rose Jenkins confirmed by a vote of 69-17
September 24, 2024
News
Application period for 2024 environmental justice solar and wind capacity limitation program closing soon
Application period will close for most low-income community projects on October 10, and for projects located on Indian Lands on November 12.
September 24, 2024
News
KPMG reports: California (sourcing rules for professional services); New York (NYC business corporation tax); Texas (sales and use tax on data process services)
KPMG This Week in State Tax focuses on recent state and local tax developments.
September 23, 2024
News
Panama: Further extension of CRS filing deadline to September 25
Deadline was previously extended to September 2, 2024
September 23, 2024
News
KPMG article: Reconsidering maquiladoras in light of recent tax reforms in Mexico
Why businesses may need to reconsider their Maquiladora tax regime structures
September 23, 2024
News
Notice 2024-68: Per diem rates, substantiation of employee lodging, meals, incidentals (2024-2025)
Special per diem rates for taxpayers to use in substantiating the amount of ordinary and necessary business expenses incurred while traveling
September 20, 2024
News
Australia: Increased reporting requirements for Local file
Proposed Local file and Master file XML schema 4.0
September 20, 2024
News
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
News
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
News
KPMG comments on European Commission consultation on ATAD
Evaluation of the Anti-Tax Avoidance Directive
September 19, 2024
News
UK: European Commission’s finding of unlawful State aid annulled, judgment of General Court set aside (CJEU judgment)
The CJEU found that the EC and the General Court erred in law.
September 19, 2024
News
U.S. House passes bill increasing penalties for illegal tax disclosures
H.R. 8292, the “Taxpayer Data Protection Act”
September 18, 2024
News
U.S. Tax Court: Commutation of marital trust results in gifts to surviving spouse of remainder interests in trust
Commutation of a QTIP marital trust to other trusts for the benefit of children in exchange for promissory notes payable to the surviving spouse
September 18, 2024
News
Rev. Proc. 2024-37: Guidance on filing claims for recovery of overpayments related to tax-exempt and other tax-advantaged bonds
Claims must be filed using Form 8038-R
September 18, 2024
News
IRS provides tax relief for taxpayers in Pennsylvania affected by Tropical Storm Debby
Taxpayers now have until February 3, 2025, to file various individual and business tax returns and make tax payments.
September 18, 2024
News
Poland: Right to deduct input VAT on vehicles; correcting sales when supply at overstated VAT rate (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
September 18, 2024
News
Cambodia: New procedures for postal and express consignments
GDCE updates related to customs procedures for postal, express consignments, and cross-border electronic trade of goods
September 18, 2024
News
Serbia: Updates on electronic recording of input VAT
Internal Technical Manual updated to reflect the changes
September 18, 2024
News
Malta: Overview of tax system
A 2024 report that provides an overview of Malta’s tax system.
September 17, 2024
News
OECD: Annual peer review of BEPS Action 13 minimum standard on country-by-country reporting
Key findings from the OECD report
September 17, 2024
News
Egypt: Overview of changes to permanent establishment provisions
Recent updates and implications of the permanent establishment provisions in Egypt
September 17, 2024
News
KPMG article: Understanding and navigating requirements of the corporate alternative minimum tax (CAMT) and proposed regulations
Taxpayers and tax professionals alike are still struggling with both the idea that it might affect them and how to deal with the innumerable requirements of the new regime.
September 17, 2024
News
Philippines: Tax assessment notices not received by taxpayer were invalid (Supreme Court decision)
Assessment notices were invalid because they were not served to authorized representatives
September 16, 2024
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Notices of filing of petitions for addition of seven glycol ethers to Superfund list
Petitions have been filed requesting that seven glycol ethers be added to the list of taxable substances under section 4672(a)
August 30, 2024
News
Moldova: Amendments to corporate income tax, VAT, and transfer pricing rules
Amendments to certain provisions of the Moldovan Fiscal Code with effect from January 1, 2025
August 29, 2024
News
Australia: Update on corporate tax transparency reporting for 2022-2023 and onwards
2022-2023 will be the first year that data will be reported
August 29, 2024
News
Rev. Proc. 2024-34: Expanded waiver of eligibility rules to accounting method changes to address short tax years
Obtaining automatic consent to change accounting methods for expenditures paid or incurred in tax years starting after December 31, 2021
August 29, 2024
News
Full applications for qualifying advanced energy project tax credit due by October 18
Applicants who submitted a concept paper can now submit full applications on the 48C portal.
August 29, 2024
News
IRS provides tax relief for taxpayers throughout U.S. Virgin Islands affected by Tropical Storm Ernesto
Tax relief for individuals and businesses throughout the U.S. Virgin Islands affected by Tropical Storm Ernesto.
August 28, 2024
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News
Portugal: Withholding tax on dividends to nonresident investment funds contrary to EU law
Supreme Administrative Court decision
July 31, 2024
News
Poland: Domestic rules implementing DAC6 unconstitutional to extent tax advisors obliged to violate professional secrecy
A Constitutional Tribunal decision concerning domestic rules implementing DAC6 unconstitutional.
July 31, 2024
News
Poland: Free-of-charge delivery of goods, costs of fixed asset not eligible costs, tax exemption and withholding tax, procurement arrangement services (Supreme Administrative Court decisions)
Summaries of recent Supreme Administrative Court decisions
July 31, 2024
News
Belgium: Mandatory disclosure rules (DAC6) compatible with EU law (CJEU judgment)
CJEU confirmed validity of mandatory automatic exchange of information for cross-border arrangements
July 31, 2024
News
IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, landslides, and mudslides in Kentucky
Various deadlines postponed to February 3, 2025
July 31, 2024
News
Philippines: Foreign shipping companies entitled to VAT zero-rating (Supreme Court decision)
A Supreme Court decision concerning whether foreign shipping companies were entitled to VAT zero-rating.
July 30, 2024
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News
Argentina: Extension of FATCA and CRS deadline
Deadline for submitting FATCA and CRS reports for the 2023 reporting period has been extended to July 31, 2024
August 28, 2024
News
U.S. Supreme Court: Chevron overruled
Courts will no longer be bound to uphold IRS regulations as authoritative interpretations of ambiguous provisions under the Code.
June 28, 2024
News
South Carolina: Durable medical equipment sales and use tax exemption prospectively invalidated (Supreme Court decision)
A Supreme Court decision concerning the state’s durable medical equipment sales and use tax exemption.
June 28, 2024
News
Cyprus: Extended deadline for individual income tax returns for 2023
The tax authority extended until October 31, 2024, the deadline for filing individual income tax returns for 2023 and payment of associated tax due.
June 28, 2024
News
Australia: Updated advice on waiver of 2020-2021, 2021-2022 payroll taxes for eligible employers (Victoria)
Victoria’s tax authority issued updated advice on its waiver of payroll taxes for eligible employers as a result of the coronavirus pandemic.
June 27, 2024
News
KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions
Initial analysis and observations
June 27, 2024
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IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas (updated)
Tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas
June 12, 2024
News
OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
News
IRS provides tax relief for taxpayers in Massachusetts affected by severe storms, flooding
Tax relief for individuals and businesses in parts of Massachusetts affected by severe storms and flooding that began on September 11, 2023.
May 31, 2024
News
Poland: Intra-community VAT supply of construction materials; issuance of invoice for bad debt relief (court decisions)
Summaries of recent court decisions
May 30, 2024
News
India: Taxation of foreign branch at higher rate not prevented by non-discrimination article of treaty (High Court decision)
Netherlands bank taxed at higher corporate tax rate than that applicable to domestic company
May 30, 2024
News
U.S. Tax Court decision interpreting section 7508A(d)’s automatic and mandatory extension for filing a petition
KPMG report discusses the Tax Court’s decision in Abdo & Farah v. Commissioner
May 29, 2024
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Slovakia: Guidelines on transfer pricing documentation for 2023
The Ministry of Finance released guidelines on the content of transfer pricing documentation for 2023.
April 30, 2024
News
Rev. Proc. 2024-23: Updated annual list of automatic accounting method changes
Effective immediately for Forms 3115 filed on or after April 30, 2024, for a year of change ending on or after September 30, 2023
April 30, 2024
News
Reference price for nonconventional source production credit for 2023
Reference price under section 45K(d)(2)(C) for calendar year 2023 is $76.10
April 29, 2024
News
Notice 2024-36: Announcement of 2024 allocation round and updated guidance on qualifying advanced energy project credit
Guidance for upcoming 2024 allocation round of qualifying advanced energy project credit program under section 48C(e)
April 29, 2024
News
OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
News
Tennessee: Franchise tax refund agreement reached
The governor is expected to sign the legislation.
April 26, 2024
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Canada: Relief for bare trusts from new information reporting requirements
Bare trusts will no longer have to meet new trust information reporting obligations for their 2023 tax year
March 29, 2024
News
KPMG report: New UK transfer pricing guidance on allocation of risk in controlled transactions
HMRC’s guidance sets out its views on issues pertaining to the OECD Transfer Pricing Guidelines.
March 29, 2024
News
Netherlands: Public country-by-country reporting implemented
Public CbC reporting rules apply to financial years starting on or after 22 June 2024.
March 29, 2024
News
Announcement 2024-16: APMA program, APA statistics for 2023
25th report describing the experience, structure, and activities of the APMA program
March 29, 2024
News
South Africa: FATCA and CRS third party data submission period
The South Africa Revenue Service announced the opening of its third party data annual submissions process.
March 28, 2024
News
South Africa: Comparable uncontrolled price method held most reliable method (court decision)
A court decision concerning whether comparable uncontrolled price method was the most reliable method.
March 28, 2024
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Senate confirms Marjorie Rollinson to be IRS Chief Counsel
IRS has been without a chief counsel since the start of the Biden Administration.
February 29, 2024
News
Nigeria: NMDPRA’s right to impose and collect certain levies upheld (Federal High Court decision)
Authority to enact regulations related to the administration of midstream and downstream petroleum liquids operations
February 29, 2024
News
Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended
Deadline extended to 30 November 2024
February 29, 2024
News
IRS announces new effort focused on high-income non-filers
New initiative will begin with IRS compliance letters going out this week
February 29, 2024
News
IRS LB&I division adds new compliance campaign (business aircraft)
Addresses compliance concerns related to business aircraft usage by large corporations, large partnerships, and high-income taxpayers
February 29, 2024
News
Romania: FATCA and CRS reporting deadline is 15 May 2024
A press release advising reporting financial institutions to report annual data for FATCA and CRS by 15 May 2024
February 28, 2024
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Finland: FATCA and CRS annual information returns due 31 January 2024
The deadline for submitting FATCA and CRS annual information returns for 2023 is 31 January 2024.
January 31, 2024
News
KPMG report: New year, changing information reporting and withholding (IRW) requirements
How organizations can prepare for electronic filing requirement threshold changes
January 31, 2024
News
House passes bipartisan tax extenders legislation
U.S. House of Representatives passed H.R. 7024, the “Tax Relief for American Families and Workers Act of 2024”
January 31, 2024
News
Australia: Guide on details of R&D tax transparency reports
What and when R&D information will be published, common errors, and how to make amendments
January 31, 2024
News
UK: Updated transfer pricing guidance on allocation of risk in controlled transactions
HM Revenue & Customs (HMRC) updated transfer pricing guidance
January 30, 2024
News
Poland: Procedure for filing transfer pricing reporting forms for acquired entities
The Ministry of Finance issued a notice regarding the procedure for submitting transfer pricing reporting forms for acquired entities.
January 30, 2024
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