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KPMG Week in Tax: September 2 – 6, 2024

Recent tax developments from around the globe for the week of September 2 – 6, 2024

September 6, 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: A KPMG report outlines many provisions that are set to expire at the end of 2025 that will have a particular impact on individual taxpayers. Read TaxNewsFlash
  • Peru: The tax authority issued Resolution No. 173-2024/SUNAT providing rules—effective September 1, 2024—for registration in the single taxpayer registry of nonresidents designated as withholding or collection agents of value added tax (VAT) on the cross-border provision of digital services and the import of intangible goods. Read TaxNewsFlash
  • Netherlands: The Court of Justice of the European Union (CJEU) on September 5, 2024, held in joined cases C-639/22 to C-644/22 that certain Dutch pension funds may qualify as “special investment funds,” such that management services provided to such funds are exempt from VAT. Read TaxNewsFlash

United States

  • Notice 2024-65: Comments requested regarding saver’s match contributions under section 6433
  • Rev. Proc. 2024-35: Premium tax credit percentage table for 2025
  • KPMG report: Tax provisions expiring in 2025 affecting individuals and families
  • Comment period reopened for proposed regulations on payment of tax by commercially acceptable means
  • Correction to proposed regulations on elections relating to foreign currency gains and losses
  • United States: IRS requests certain FATCA IDES users to retransmit files

Read TaxNewsFlash-United States

Transfer Pricing

  • Bahrain: Legislation implementing Pillar Two global minimum tax rules
  • Belgium: Prepayment system for Pillar Two taxes now operational
  • Italy: Amended deadline for income tax returns, implications for transfer pricing documentation

Read TaxNewsFlash-Transfer Pricing

Americas

  • Peru: Guidance on registration of nonresident withholding agents of VAT on cross-border provision of digital services

Read TaxNewsFlash-Americas

Asia Pacific

  • Korea: Taxpayer not entitled to foreign tax credit for illegitimately withheld tax (Tax Tribunal decision)
  • Australia: KPMG comments on proposed food donation tax offset legislation
  • Australia: Senate Economics Committee report on build-to-rent tax incentive bills
  • Saudi Arabia: E-invoicing requirement extended to 15th group of taxpayers from March 1, 2025
  • Australia: Guidance on employee versus independent contractor for income tax and superannuation guarantee purposes
  • Australia: Guidance on payroll tax exemption for general practitioners in medical centers (New South Wales)
  • India: Exemption from capital gains on transfer of shares available under India-Mauritius treaty (High Court decision)

Read TaxNewsFlash-Asia Pacific

Europe

  • Cyprus: Withholding tax declarations for 2019 onwards may be submitted by October 31, 2024 without penalty
  • Cyprus: Zero VAT on specific goods extended to September 30, 2024; postponement of VAT objection submissions through TFA portal
  • Netherlands: Pension funds may qualify as special investment funds eligible for VAT exemption (CJEU judgment)
  • Luxembourg: Bill including VAT measures presented to Parliament
  • Serbia: Amended VAT rulebook adopted
  • Albania: New compliance procedures for application of income tax treaties
  • Italy: Amended deadline for income tax returns, implications for transfer pricing documentation
  • Poland: Permanent establishment; non-compete compensation not subject to VAT; 0% VAT on intra-community supplies (Supreme Administrative Court decisions)

Read TaxNewsFlash-Europe

Trade & Customs

  • U.S. BIS implements export controls on semiconductor, quantum, and additive manufacturing items
  • U.S. OFAC issues Russia-related general licenses

Read TradeNewsFlash-Trade & Customs

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Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

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 upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

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