KPMG Week in Tax—published weekly to provide an overview of tax developments as reported in TaxNewsFlash—includes summaries of select tax-related news followed by a full list of reports (more information can be found at the links provided).

  • Greece: A new law introduces several tax provisions including reduced rates for certain taxes, penalties for cash payments over €500, taxation of personal businesses and freelancers, and incentives for electronic invoicing. It also includes provisions for real estate transactions, climate crisis resilience duty, and deductions for building renovation costs. Read TaxNewsFlash

  • Hong Kong: The government published a consultation paper on the implementation of the Pillar Two global minimum tax from 2025 onwards. The paper outlines the government's proposals for the legislative approach and administrative framework, including the definition of a Hong Kong resident entity, the application of the global anti-base erosion (GloBE) rules, and the design and administration of the Hong Kong minimum top-up tax (HKMTT). The consultation period will last for three months, ending on 20 March 2024. Read TaxNewsFlash

  • United States: The IRS released a legal advice memorandum on the impact of group membership on the interest rate for intragroup loans under section 482. The IRS concluded that if an unrelated lender would consider group membership in setting financing terms for the borrower, even without a formal guarantee, the IRS may adjust the interest rate in a controlled lending transaction to reflect that implicit support. This could result in a decreased interest rate for a U.S. subsidiary of a foreign-parented group. The IRS clarified that this analysis would also apply to loans between controlled parties with relationships other than parent-subsidiary, which might include implicit support from the group. Read TaxNewsFlash

Additional reports

United States

  • IRS announces more time for dealers and sellers of clean vehicles to submit time-of-sale reports
  • Federal Circuit: Butane not eligible for alternative fuel mixture tax credit
  • Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)
  • IRS annual revenue procedures for 2024
  • KPMG report: Proposed regulations on clean hydrogen production credit and related energy credit

Read TaxNewsFlash-United States

Transfer Pricing

  • Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax
  • KPMG report: Pillar Two rules and the asset management industry
  • Qatar: Extended deadline for country-by-country reports and notifications
  • United States: Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Senegal: Commitment to start automatic exchange of information (AEOI) by 2025

Read TaxNewsFlash-FATCA / IGA / CRS

Americas

  • Bolivia: 2024 budget law includes tax measures
  • Bolivia: Guidance on tax incentives for import and marketing of capital goods and industrial plants
  • Bolivia: Procedure for zero rate VAT billing

Read TaxNewsFlash-Americas

Asia Pacific

  • India: Guidelines for withholding tax on e-commerce transactions
  • Malaysia: Direct and indirect tax changes in Finance Act (No. 2) 2023
  • Malaysia: Guidance on sales tax exemptions for manufacturing aids and cleanroom equipment
  • Malaysia: New indirect tax guidance effective 1 January 2024
  • Saudi Arabia: Guidance on resident natural persons subject to income tax
  • Vietnam: Reduced VAT through June 2024

Read TaxNewsFlash-Asia Pacific

Europe

  • Greece: Tax provisions in new law
  • Netherlands: Farewell bonuses not treated as non-deductible participation selling costs (Supreme Court decision)
  • North Macedonia: New rulebook on VAT registration of foreign taxpayers through a tax representative
  • Serbia: Amendments to VAT rulebook
  • Sweden: Revaluation of tax base for VAT purposes for group-wide services (CJEU referral)

Read TaxNewsFlash-Europe

The items described above are also reported as editions of TaxNewsFlash:

 

 

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