Article Posted date
15 March 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).
- United States: Treasury released its “Green Book” explaining the tax proposals in the Biden Administration’s FY 2025 budget. Most of the administration’s revenue proposals are familiar, having been included in previous budgets. However, the administration unveiled new proposals in a few areas including proposals to increase in the corporate alternative minimum tax (CAMT), limit depreciation and increase certain fuel taxes for some private planes, create a new tax credit for certain first-time homebuyers, and modify deadlines for certain information returns. KPMG LLP has prepared a 113-page report providing analysis and observations of these tax proposals and more contained in the Green Book. Read TaxNewsFlash
- United States: The U.S. Treasury Department announced that in light of the revised timeline for adoption and signature of the Pillar One multilateral convention (MLC), the United States and Turkey have decided to apply to their 22 November 2021 joint statement regarding their political agreement on transitioning from the existing Turkish digital services tax (DST) to Pillar One—which incorporated by reference the terms under the 21 October 2021 joint statement between the United States and Austria, France, Italy, Spain, and the United Kingdom regarding their political agreement to withdraw all unilateral measures concerning the imposition of DSTs once Pillar One takes effect—the same terms as those under that 21 October 2021 joint statement updated as of 15 February 2024 to extend the agreement from 23 December 2023 until 30 June 2024. Read TaxNewsFlash
- Jamaica: The 2024-2025 budget did not include any “new taxes,” but the government did commit to introducing a qualified domestic minimum top-up tax (QDMTT) in line with the Pillar Two global minimum tax rules. The domestic legislation is not yet in place, and it is expected that these changes will be seen in financial year 2024/2025. These measures would only apply to Jamaican taxpayers with a tax rate below 15%, such as companies operating in a special economic zone which have a corporate income tax rate of 12.5%. Read TaxNewsFlash
- Czech Republic: A draft amendment to the value added tax (VAT) law would transpose various EU directives and respond to rulings of the Court of Justice of the European Union (CJEU). In particular, the draft amendment would remove certain activities from the list of VAT-exempt financial activities. Read TaxNewsFlash
Additional reports
United States
- KPMG report: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget
- Senate Finance hearing on administration’s FY 2025 budget with Treasury Secretary Yellen
- Treasury releases “Green Book” explanation of tax proposals in FY 2025 budget
- Administration releases FY 2025 budget recommendations
Read TaxNewsFlash-Legislative Updates
- Final rule: Responsibility for administering alcohol taxes moved from CBP to Treasury
- IRS adds FAQ to QI / WP / WT FAQs website
- United States and Turkey announce updated digital services tax agreement
- KPMG report: New beneficial ownership information reporting requirements
- KPMG report: Final regulations on direct pay of certain tax credits under IRA, observations and analysis
- KPMG report: New proposed regulations on bad debt deductions for certain qualifying entities
- KPMG reports: Colorado (manufacturing exemption); New Mexico (individual and corporate income tax changes); New York (taxable information services)
Transfer Pricing
- Australia: Taxpayer failed to meet burden of proof in transfer pricing dispute (Full Federal Court decision)
- Cyprus: Draft legislation implementing Pillar Two global minimum tax rules
- Estonia: Draft bill implementing public country by country reporting submitted to Parliament
- EU: European Parliament committee adopts report on transfer pricing directive
- EU: Taxpayer appeals General’s Court dismissal of challenge to EU minimum tax directive
- Italy: Transfer pricing requirements for investment manager exemption
- Jamaica: Tax measures in 2024-2025 budget include Pillar Two global minimum tax rules
- Malta: Guidance on implementation of Pillar Two global minimum tax
- UK: Finance Act 2024 includes amendments to Pillar Two minimum tax rules
- United States: Updated digital services tax agreement with Turkey
Africa
- Kenya: New platform for non-VAT registered taxpayers to electronically generate and send invoices
- Namibia: Tax measures in budget 2024-2025
- Nigeria: Introduction of self-registration module on electronic platform
Read TaxNewsFlash-Africa
Americas
- Bolivia: Guidance on correction of invoices in the registry of purchases and sales
- Bolivia: Guidance on exemption from financial transactions tax for certain diplomatic organizations
- Canada: Tax measures in 2024 budget (Quebec)
- Jamaica: Tax measures in 2024-2025 budget
Asia Pacific
- Australia: Draft legislative instruments on filing requirements for 2024 returns
- Australia: General anti-avoidance rule did not apply to taxpayer’s distribution of income (Full Federal Court decision)
- Australia: Guidance on applying for variations from foreign resident capital gains withholding
- Bahrain: Tax treaty and investment protection agreement signed with Hong Kong
- India: Service permanent establishment; provision of cloud-based software-driven platform as technical services (court decisions)
- Malaysia: Guidance on exemption from service tax for certain logistics services
- Malaysia: Summary of income and indirect tax developments (March 2024)
- New Zealand: Amendments to 39% trust tax rate proposal
- New Zealand: Amendments to May 2023 Tax Bill
- UAE: New proposed law on taxation of foreign banks (Dubai)
Europe
- Cyprus: Compliance campaign for stamp tax liability
- Cyprus: Guidance on submission of data to register of beneficial owners
- Cyprus: Notional interest deduction “reference rates” for 2024
- Czech Republic: Beneficial ownership of royalties; VAT exemption for intra-community supply; proof of “essential costs” (Supreme Administrative Court decisions)
- Czech Republic: Draft amendments to VAT law include narrowing of exemptions for financial activities
- EU: European Parliament committee adopts opinion on FASTER proposal
- EU: VAT obligations of digital platforms pre-2015 (CJEU referral)
- France: VAT recovery for Olympics operators with new expenses in France
- Germany: Updated guidance on permanent establishments
- Italy: New tax credit for energy saving investments
- Latvia: Updated domestic list of low-tax or tax-free jurisdictions
- Poland: Bill introducing cap on individual capital gains tax submitted before Sejm
- Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition
- Poland: General working time not eligible for R&D relief (Supreme Administrative Court decision)
Read TaxNewsFlash-Europe
FATCA / IGA / CRS
- British Virgin Islands: CRS categorization update in BVIFARS portal
- British Virgin Islands: Deployment of payment module on BVIFars portal postponed
- Liechtenstein: Updated AEOI correction and deletion procedures
- UK: Consultation on cryptoasset reporting framework (CARF) and CRS amendments
- United States: IRS adds FAQ to QI / WP / WT FAQs website
Trade & Customs
- Australia: Consultation on removal of “nuisance tariffs”
- Cambodia: Revised guidelines for identifying goods and inspecting procedures
- Trade agreement between India and the European Free Trade Association (EFTA)
- U.S. BIS imposes stricter export controls on items destined for Nicaragua
- USTR releases FY 2025 budget justification
The items described 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.