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KPMG Week in Tax: 26 February – 1 March 2024

Recent tax developments from around the globe for the week of 26 February – 1 March 2024

March 1, 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: The U.S. Senate voted to confirm Marjorie Rollinson to be IRS Chief Counsel. Read TaxNewsFlash
  • EU: Several EU member states submitted reasoned opinions to the European Commission (EC) or adopted statements raising concerns with respect to the new common corporate tax system (BEFIT) proposal. Read a KPMG report
  • Saudi Arabia: The ministerial resolution outlining new tax incentives for regional headquarters was published in the official gazette and entered into force. Read a KPMG report
  • South Africa: The South African Government published the draft Global Minimum Tax Bill and the draft Global Minimum Tax Administration Bill to implement the OECD’s Pillar Two Model Rules. Read a KPMG report

Additional reports

United States

  • IRS announces new effort focused on high-income non-filers
  • IRS LB&I division adds new compliance campaign (business aircraft)
  • IRS provides tax relief for taxpayers in California affected by severe storms, flooding
  • IRS provides tax relief for taxpayers in Washington State affected by wildfires
  • Notice 2024-26: Administrative exemption from requirement to electronically file Form 1042
  • Notice of filing of petition for addition of iso-butanol to Superfund list
  • Rev. Proc. 2024-15: Guidance on qualifying securitizations by public utilities
  • Senate confirms Marjorie Rollinson to be IRS Chief Counsel
  • KPMG report: Challenges and opportunities faced by CAMT “scope bubble corporations”
  • KPMG report: Post-pandemic state tax policies
  • KPMG reports: Alaska (marketplace facilitators sales tax); Louisiana (industrial tax exemption program); New York (wine producer as qualified manufacturer); Wisconsin (withholding on software licensing income)

Transfer Pricing

  • Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended
  • Greece: Proposed legislation implementing Pillar Two global minimum tax
  • Malta: Legislation implementing Pillar Two global minimum tax
  • OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
  • South Africa: Draft legislation implementing Pillar Two global minimum tax

Africa

  • Nigeria: NMDPRA’s right to impose and collect certain levies upheld (Federal High Court decision)
  • South Africa: Draft legislation implementing Pillar Two global minimum tax
  • Republic of the Congo: VAT on cross-border provision of digital services
  • South Africa: Summary of direct and indirect tax proposals in 2024 budget
  • Africa: Summary of tax developments (February 2024)

Americas

  • Canada: Tax measures in 2024 provincial budgets (Alberta, Nova Scotia, Prince Edward Island)
  • Colombia: Corporate compliance for legal entities with presence in Colombia (2024)

Asia Pacific

  • Australia: Individual income tax and medicare levy bills pass both Houses of Parliament
  • Australia: Rental bond data matching program updated
  • Azerbaijan: Designation of strategic investment projects qualifying for tax benefits
  • Azerbaijan: Electronic accounting required for certain entities
  • Hong Kong: Direct and indirect tax proposals in 2024-2025 budget
  • India: Guidance on waiver of certain outstanding direct tax liabilities
  • Korea: Software fees paid to Irish affiliate treated as royalties paid to U.S. parent (Tax Tribunal decision)
  • Malaysia: Expansion of services subject to service tax
  • Malaysia: Service tax policies and FAQs
  • Saudi Arabia: Tax incentives for regional headquarters
  • UAE: Timelines for corporate tax registration

Europe

  • Belgium: Application of anti-abuse provision upheld even though taxpayer not involved in all parts of transaction (Supreme Court decision)
  • Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended
  • Cyprus: Guidance on submission of data to register of beneficial owners
  • EU: Member states submit opinions to EC on new common corporate tax system proposal (BEFIT)
  • Germany: Compromise tax reform bill adopted by mediation committee of Parliament, other tax developments
  • Germany: Guidance on division of input VAT using overall sales key, other VAT developments
  • Ireland: Comments on public consultation on introduction of participation exemption
  • Latvia: Tax card for 2024
  • Poland: Payments to employees on leave qualify as eligible R&D expenses
  • Poland: Social security liability; reduction in depreciation rates for prior years; taxable base for real estate taxes (court decisions)
  • Serbia: Individual income tax filing deadlines and rates for 2023
  • Switzerland: Draft law to reduce wealth tax on shares of unlisted companies held by entrepreneurs (Geneva)
  • UK: “Spring Budget” expected 6 March 2024
  • UK: Closure notice held valid (First-tier Tribunal decision)
  • UK: Draft guidance on overseas restrictions, subcontracted rules under new merged R&D tax relief regime

FATCA / IGA / CRS

  • Hungary: Updated CRS filing instructions
  • Hungary: Updated FATCA filing instructions
  • Romania: FATCA and CRS reporting deadline is 15 May 2024
  • Switzerland: Suspension of tax information with Hong Kong and Singapore
  • United States: Administrative exemption from requirement to electronically file Form 1042

Trade & Customs

  • President Biden’s 2024 trade agenda presented to Congress
  • U.S. BIS revises EAR entity list

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

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