Article Posted date
24 May 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).
- Belgium: The tax authorities released details about the global anti-base erosion (GloBE) registration requirements for multinational enterprises (MNEs) and large-scale domestic groups. The responsibility of registration lies with the Belgian ultimate parent entity (UPE) or the Belgian constituent entity (CE) if there is no UPE. In cases where there are multiple UPEs or CEs, the entity appointed by the others is responsible. The registration applies even if there is no Belgian UPE. Read TaxNewsFlash
- Italy: The tax authorities issued regulations implementing the optional payment of a 15% substitute tax, which offers an alternative to the application of controlled foreign company (CFC) rules. Read a KPMG report
- UK: HMRC published guidance on Pillar Two registration requirements for in-scope multinational groups operating in the UK, including a notice that includes information on how to register for Pillar Two top-up taxes in the UK, what is required to be provided, and how to notify HMRC of any reporting related changes. Read a KPMG report
Additional reports
United States
- Notice 2024-43: Further deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments
- Notice 2024-44: Further extended phase-in provisions under section 871(m) regulations
- U.S. Tax Court: Option granted to related entity with respect to real property not a sham
- U.S. Tax Court: No gift tax liability following termination of marital trusts
- U.S. Treasury release: No change to list of countries cooperating with international boycott
- IRS provides tax relief for taxpayers affected by storms and tornadoes in Iowa
- IRS provides tax relief for taxpayers affected by storms and tornadoes in Nebraska
- KPMG report: Income tax disclosures—applying recent disaggregation enhancements
- KPMG reports: Alabama (accommodations intermediaries legislation); California (budget revisions); Tennessee (local sales taxes on food)
Read TaxNewsFlash-United States
- JCT overview of federal tax system (2024)
- House passes disaster tax relief bill
- Senate Finance hearing on tax-advantaged accounts benefiting children; JCT description of present law and data
Transfer Pricing
- Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
- Belgium: GloBE registration requirements for multinational and large domestic groups
- Crown Dependencies: Details on plans to implement Pillar Two global minimum tax
- Denmark: Proposed amendments to Pillar Two legislation submitted to Parliament
- Poland: Consultation on Pillar Two global minimum tax rules extended
- Spain: Consultation on draft legislation implementing Pillar Two global minimum tax
- Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax
- UK: HMRC guidance on registration under Pillar Two global minimum tax regime
Asia Pacific
- Australia: Commercial and industrial property tax reform passed by Parliament (Victoria)
- Australia: Draft legislation extending fringe benefit tax exemption for electric vehicles introduced in Senate
- Australia: FY 2023-2024 income tax filing requirements
- Australia: Guide on how to avoid unexpected tax consequences in relation to “Division 7A” loan repayments
- Australia: New ad valorem mineral royalty scheme (Northern Territory)
- Australia: Payroll tax changes (Victoria, South Australia, and Tasmania)
- Australia: Proposal to prohibit decreases in coal royalty rates without legislative action (Queensland)
- Australia: Proposed exemptions from sharing economy reporting regime
- Bahrain: Updated VAT real estate guide
- China: Guidance on employer equity incentives
- India: Interest paid by permanent establishment to overseas head office not taxable under India-France treaty (tribunal decision)
- Korea: Permanent establishment found based on cost and profit sharing agreement (Tax Tribunal decision)
- UAE: Corporate tax guide on free zone regime
Europe
- Cyprus: Applications for reduced VAT rate on supply or construction of private dwelling must be submitted online beginning 27 May
- EU: EC Directorate-General for Taxation and Customs Union management plan 2024
- EU: European Commission public consultation on directive on administrative cooperation (DAC)
- France: Claim for cross-border loss relief denied (Supreme Administrative Court decision)
- France: Taxation of assets held abroad (CJEU referral)
- Italy: Regulations implementing 15% substitute tax to controlled foreign company taxation
- Netherlands: Financial instrument treated as equity (Supreme Court decision)
- Poland: Excise duty on leased cars provided to employees; taxation of employee accommodation benefits; taxation of family foundation (court decisions)
- Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax
- UK: Denial of R&D tax incentives upheld (First-tier Tribunal decision)
- KPMG report: Comments on consultation on UK tax administration framework
Read TaxNewsFlash-Europe
Americas
- Chile: Tax treatment of income from import and distribution agreement; other direct and indirect tax developments
Africa
- Kenya: Gains on petroleum products not subject to additional import duties (High Court decision)
- Southern Africa: Summary of grants and tax incentives (Botswana, Mauritius, Mozambique, South Africa, Zambia, Zimbabwe)
Read TaxNewsFlash-Africa
FATCA / IGA / CRS
- Bermuda: Updated CRS independence compliance review guidelines
- British Virgin Islands: Payment feature update for BVIFars portal
- Finland: Correction to FATCA and CRS annual information returns for 2023
- Italy: Updated CRS technical guidance
- Panama: Registration and deactivation process for FATCA and AEOI portal
Trade & Customs
- Kenya: Gains on petroleum products not subject to additional import duties (High Court decision)
- Mexico: Updated criteria for importation of “sensitive goods” under 8th rule
- United States: USTR extends certain exclusions from China Section 301 tariffs
- United States: Proposed tariff modifications and machinery exclusion process, following China Section 301 investigation four-year review
Exempt Organizations
- Rev. Proc. 2024-22 and Rev. Rul. 2024-10: Prior guidance that certain requirements for tax-exempt status satisfied under state law obsoleted due to material change in law
The items described above are also reported as editions of TaxNewsFlash:
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