Article Posted date
12 January 2024
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).
- France: The French Finance Act (FFA) for 2024, effective since its publication in the official gazette, introduces several significant measures affecting companies including the implementation of the EU Directive on Pillar Two into domestic law, the adjustment of the phasing out timetable for the contribution on companies’ added value (CVAE) between 2024 and 2027, and the introduction of a new tax credit for investments in “green industries.” The finance law also aligns the parent-subsidiary regime with EU law and strengthens transfer pricing documentation requirements. Read TaxNewsFlash
- United States: Notice 2024-19 provides penalty relief for partnerships with unrealized receivables or inventory items that fail to furnish Part IV of Form 8308 by 31 January 2024. This relief applies to a section 751 exchange that occurred in 2023. The relief does not apply to filing Form 8308 as an attachment to a partnership's Form 1065, and does not provide relief from penalties for failure to file correct information returns. Read TaxNewsFlash
- Korea: The National Assembly passed the 2023 tax reform proposal, which includes amendments to the Korean Pillar Two global minimum tax rules. The amendments delay the undertaxed payment rule (UTPR) until 2025 and incorporate elements of the OECD's global anti-base erosion (GloBE) model rules. The Ministry of Economy and Finance also enacted an amendment by presidential decree relating to the GloBE rules. Further amendments and enforcement regulations under the GloBE rules are expected to be announced in February 2024. Read TaxNewsFlash
- Philippines: The Ease of Paying Taxes (EOPT) Act was signed into law by the president on 5 January 2024 and will become effective on 22 January 2024. The EOPT Act introduces various measures to facilitate tax compliance, including measures related to income tax, business tax, and value added tax (VAT). Read TaxNewsFlash
Additional reports
United States
- IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships
- Notice 2024-18: Updated guidance on availability of administrative exemptions from requirement to file electronically
- Notice 2024-22: Initial guidance on pension-linked emergency savings accounts
- Updated beneficial ownership information reporting FAQs
- IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships
- Notice 2024-19: Additional time and penalty relief for partnerships to provide complete Forms 8308 for 2023 section 751(a) exchanges
- IRS announces changes to QI / WP / WT FAQs website
- Fourth Circuit: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed
- National Taxpayer Advocate report to Congress identifying taxpayer problems
- KPMG report: Accounting for income taxes considerations for the implementation of the Bermuda corporate income tax
- KPMG reports: Florida (sales and use tax); New York (corporate franchise tax reforms); multistate (P.L. 86-272)
Read TaxNewsFlash-United States
- JCT list of expiring federal tax provisions, 2024 – 2034
Transfer Pricing
- France: Tax-related provisions in finance law for 2024, including Pillar Two rules and transfer pricing documentation changes
- KPMG report: Comments on European Commission consultation on transfer pricing initiative
- Korea: Amendments to Pillar Two rules enacted
- Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates
FATCA / IGA / CRS
- United States: IRS announces changes to QI / WP / WT FAQs website
Trade & Customs
- United States: CBP modifies test concerning entry of Section 321 low-value shipments through ACE
- Canada: Updated list of imported goods targeted for potential audits
- Romania: New reporting requirements for international shipment of goods
Americas
- Mexico: Updates to presentation of 2023 annual declaration of legal entities
- Mexico: Miscellaneous tax resolution for 2024 regarding payroll electronic invoices (CFDI)
- Mexico: Tax measures in miscellaneous fiscal resolution for 2024
- Canada: 2023 tax rates and other changes to consider for tax accounting purposes
- Bolivia: Deadline to implement online billing modalities for eighth, ninth, and tenth groups of taxpayers
- Bolivia: Certain taxpayers to implement online billing modality
Asia Pacific
- Vietnam: Draft decree on establishment, management, and use of investment support fund
- Malaysia: Summary of income and indirect tax developments (January 2024)
- Philippines: New law includes income tax, business tax, and VAT measures
- Cambodia: Tax, accounting, labor, and regulatory compliance reminders for 2023-2024
- Sri Lanka: Amendment to Social Security Contribution Levy Bill
Europe
- KPMG report: Comments on European Commission consultation on transfer pricing initiative
- Belgium: Law project to introduce a new e-invoicing mandate from January 2026
- Spain: Tax measures in new laws approved at end of 2023
- Sweden: Voluntary tax liability for VAT purposes appliable in context of jointly managed rental properties
- France: Tax-related provisions in finance law for 2024, including Pillar Two rules and transfer pricing documentation changes
- Cyprus: Reduced special defence contribution rate on interest
- Spain: Procedures for VAT required during January and February 2024
- Spain: Issues to be considered by financial, insurance industries when calculating VAT pro-rata for 2023
- Bulgaria: Amendments to VAT law effective 1 January 2024
- Greece: New law introduces amendments to taxation of insurance funds and pension plans
- Serbia: Amendments to rulebook on e-invoicing adopted
- Cyprus: Registration in tax registry must be done electronically through taxpayer portal
- Moldova: Fixed social security and health insurance contributions for 2024
- Poland: Refusal to apply preferential withholding tax treatment upheld; R&D conducted by contractor treated as carried out by taxpayer (Supreme Administrative Court decisions)
Read TaxNewsFlash-Europe
The items listed above are also reported as editions of TaxNewsFlash:
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.