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: Final regulations provide guidance on the treatment of property, stock, and securities in certain triangular reorganizations involving foreign corporations and subsequent inbound nonrecognition transactions, finalizing the proposed regulations from October 2023 without substantive changes. Read TaxNewsFlash
- United States: Final regulations and proposed regulations regarding required minimum distributions (RMDs) under section 401(a)(9) for various retirement plans reflect amendments from the SECURE Act and SECURE 2.0 Act. The proposed regulations reflect various provisions of the SECURE 2.0 Act reserved in the final regulations and are open for public comment. Read TaxNewsFlash
- OECD: The "selection documentation package" requirements for the International Compliance Assurance Programme (ICAP)— a program focused on multilateral risk assessment for transfer pricing and permanent establishment issues—have been published. Additionally, the OECD has indicated that the "main documentation package" and "outcome letter (template)" will be available soon. Read TaxNewsFlash
- Mexico: Foreign digital services providers are now required to include a specific corporate purpose in their bylaws, detailing their provision of technological platform services, and to submit an affidavit from their legal representative outlining the goods or services sold, the transaction website, and the business address. These new requirements, aimed at increasing transparency, add complexity to the registration process for foreign providers, necessitating review and potential modifications to existing incorporation documents. Read TaxNewsFlash
Additional reports
United States
- Final and proposed regulations: Required minimum distributions under section 401(a)(9)
- Final regulations: Guidance under section 367(b) relating to certain triangular reorganizations and inbound nonrecognition transactions
- KPMG reports: Florida (sourcing rule for intangible property); New Jersey (new corporate transit fee); Oregon (proposed increase in corporate minimum tax); Pennsylvania (increase in NOL carryforward limitation)
Transfer Pricing
- Canada: Only Federal Court can review discretionary decisions of tax authority in transfer pricing matters (Supreme Court decision)
- Italy: Decree on Pillar Two global minimum tax
- OECD: Negotiations on Pillar One multilateral convention continue
- OECD: Selection documentation package requirements for International Compliance Assurance Programme (ICAP)
Asia Pacific
- Australia: Superannuation tax updates report 2024
- Australia: Updated ATO advice on R&D tax transparency reporting
- Azerbaijan: Registration portal for VAT on cross-border provision of digital services
- Hong Kong: Stamp duty group relief only available to associated companies with issued share capital (Court of Appeal decision)
- Oman: Draft legislation imposing individual income tax
- Pakistan: Indirect tax changes in Provincial Finance Acts, 2024 (Punjab, Sindh, KPK, and Balochistan)
Europe
- Cyprus: Imposition of financial charges under beneficial ownership register on new officers, partners
- Czech Republic: Statutory representative held liable for corporation’s tax arrears (Supreme Administrative Court decision)
- EU: European Commission’s annual report on taxation
- Greece: Guidance on deductibility of commitment fees paid to banks for provision of credit
- Luxembourg: Bill including tax measures benefiting both individuals and companies presented to Parliament
- Poland: New consultations on e-invoicing system (KSeF)
- Poland: Reimbursement of costs for private car and subsidies under incentive funds are taxable (Supreme Administrative Court decisions)
- Portugal: Legislation including tax incentives for capital markets and housing approved by Parliament
- Spain: Corporate and nonresident income tax return forms for 2023
- Spain: New tax incentive for foreign individuals investing in certain securities (Madrid)
- UK: Activities qualified for R&D tax credits (First-tier Tribunal decision)
- UK: Adviser fees on disposal of subsidiary business not deductible as management expenses (Supreme Court decision)
- UK: Labour’s business tax plan includes little significant change
Read TaxNewsFlash-Europe
Africa
- Tanzania: Waiver of late fees for company documents
- Nigeria: Imposed income tax on foreign exchange transaction gains of banks
Read TaxNewsFlash-Africa
Americas
- Canada: Only Federal Court can review discretionary decisions of tax authority in transfer pricing matters (Supreme Court decision)
- Chile: Conceptual engineering costs not eligible for VAT refund on fixed assets; other direct and indirect tax developments
- Mexico: New requirements for registering foreign digital service providers
- Mexico: Tax administration challenging deductibility, VAT credits for advertising and promotional expenses
FATCA / IGA / CRS
- Bahamas: Updated CRS guidance
- United States: FATCA registration website requires authentication
Trade & Customs
- EU: Guidance on rules of origin in trade agreement with New Zealand
- U.S. CBP adjusts customs user fees for inflation (FY 2025)
- U.S. changes to scope and terms used in EAR to describe “standards-related activities”
- United States publishes updated Uyghur Forced Labor Prevention Act enforcement strategy
The items described above are also reported as editions of TaxNewsFlash:
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