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Week in Tax: September 23 – 27, 2024

Recent tax developments from around the globe for the week of September 23 – 27, 2024

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September 27, 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 IRS released Rev. Rul. 2024-22, designating Bourse de Montréal (MX) as a “qualified board or exchange” under section 1256(g)(7)(C), effective for MX contracts entered into on or after November 1, 2024. Read TaxNewsFlash
  • United Kingdom: HM Revenue & Customs published the third version of draft guidance for consultation on the UK's Pillar Two global minimum tax rules, with comments due by October 23, 2024. The draft includes new content on various topics such as attributing top-up amounts, differences between multinational top-up tax (MTT) and domestic top-up tax (DTT), and qualifying domestic minimum top-up tax (QDMTT) safe harbor. Further guidance is expected later in the year. Read TaxNewsFlash
  • Peru: Amendments to the income tax law (DL 1662 and 1663) introduce changes to the transfer pricing regime effective January 1, 2025, including the “rollback” of bilateral advance pricing agreements (APAs) to periods prior to the agreement's conclusion. Additionally, new valuation methods for shares and other assets are introduced, such as discounted cash flows (DCF), multiples, equity participation value, appraisal, and the multiperiod excess earnings method (MEEM) for assets other than shares. Read TaxNewsFlash

United States

  • Rev. Rul. 2024-22: Bourse de Montreal held “qualified board or exchange”
  • Rev. Proc. 2024-38: Guidance on income requirements for residential rental projects financed with exempt bonds and low-income housing projects
  • Application period for 2024 environmental justice solar and wind capacity limitation program closing soon
  • IRS announces new process for third-party payers to resolve incorrect employee retention credit claims
  • IRS announces manual IDES confirmations will be sent by October 15
  • KPMG report: U.S. transfer pricing and international tax year-end considerations
  • KPMG report: State, local tax changes (third quarter 2024, table format)
  • KPMG reports: California (sourcing rules for professional services); New York (NYC business corporation tax); Texas (sales and use tax on data process services)

Read TaxNewsFlash-United States

  • Senate confirms three U.S. Tax Court judges, one nominee remains

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Cyprus: Additional FAQs on new transfer pricing rules
  • Korea: Sales volume must be considered in determining comparability of transactions for transfer pricing purposes (Administrative Court decision)
  • Mexico: Reconsidering maquiladoras in light of recent tax reforms in Mexico (KPMG article)
  • Peru: Changes to APA rules and introduction of new valuation methods
  • UK: Consultation on additional draft guidance on Pillar Two global minimum tax rules
  • United States: Transfer pricing and international tax year-end considerations (KPMG report)

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • United States: IRS announces manual IDES confirmations will be sent by October 15
  • Bahamas: Updated FATCA / CRS reporting deadlines
  • Panama: Further extension of CRS filing deadline to September 25

Read TaxNewsFlash-FATCA / IGA / CRS

Africa

  • Botswana: Extended filing deadlines for annual withholding and individual income tax returns
  • Mauritius: Protocol to Bangladesh income tax treaty signed
  • Mauritius: Renewed tax amnesty scheme under Finance Act 2024

Read TaxNewsFlash-Africa

Americas

  • Chile: Updated form for large taxpayers; other direct and indirect tax developments
  • Costa Rica: New ultimate beneficial owner filing obligations
  • Mexico: Reconsidering maquiladoras in light of recent tax reforms (KPMG article)
  • Mexico: Temporary restriction of digital seal certificates for issuance of digital tax receipts
  • Peru: Changes to APA rules and introduction of new valuation methods
  • Peru: New VAT rules for nonresident digital services providers

Read TaxNewsFlash-Americas

Asia Pacific

  • Saudi Arabia: E-invoicing requirement extended to 16th group of taxpayers from April 1, 2025
  • Philippines: Guidelines for tax refunds and credits
  • Korea: Sales volume must be considered in determining comparability of transactions for transfer pricing purposes (Administrative Court decision)
  • Australia: Approved form for thin capitalisation test choice
  • Australia: Consultation on draft legislation to amend fuel-efficient vehicle definition under luxury car tax
  • Malaysia: Proposed single family office tax incentive regime for Forest City

Read TaxNewsFlash-Asia Pacific

Europe

  • Cyprus: Additional FAQs on new transfer pricing rules
  • Estonia: Amendments to Motor Vehicle Tax Act, Traffic Act
  • Germany: Draft second future financing bill, other tax developments
  • UK: Consultation on additional draft guidance on Pillar Two global minimum tax rules
  • Austria: Increased small business VAT exemption threshold; other recent direct and indirect tax developments
  • Czech Republic: Direct and indirect tax relief in response to widespread flooding

Read TaxNewsFlash-Europe

Trade & Customs

  • KPMG report: U.S. trade policy under presidential candidates Kamala Harris and Donald Trump—a comparative review
  • G7 guidance on preventing evasion of export controls and sanctions imposed on Russia
  • U.S. BIS proposed rule to address national security risks of ICTS in connected vehicles
  • U.S. BIS renews temporary denial of export privileges of Russian airline for one year
  • U.S. BIS renews temporary denial of export privileges of two Russian airlines for another year
  • U.S. CBP guidance on modifications to China tariffs under Section 301
  • United States extends suspension of Cyprus as “proscribed destination” for defense articles
  • USTR requests comments on proposed tariff increases covering tungsten products, wafers, polysilicon

Read TradeNewsFlash-Trade & Customs

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