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Week in Tax: October 14 – 18, 2024

Recent tax developments from around the globe for the week of October 14 – 18, 2024

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October 18, 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).

  • Dominican Republic: A comprehensive “fiscal modernization law” proposes reforms that include new income tax brackets, changes to VAT exemptions and rates, new excise taxes on products like tobacco and sugary drinks, modernization of tax administration, elimination or modification of various tax incentives and exemptions, and the introduction of a vehicle circulation tax and a contribution on liquefied petroleum gas. Read TaxNewsFlash
  • France: The Finance Bill for 2025 includes measures such as the phase-out adjustment of the contribution on companies’ added value (CVAE), a temporary surtax on large corporate profits, a special contribution on major shipping companies, a tax on share buy-backs, amendments to the merger preferential corporate income tax regime and employee stock options, a minimum tax on high-income taxpayers, updates to the Pillar Two global anti-base erosion (GloBE) rules, and the implementation of the DAC8 directive on cryptoassets. Read TaxNewsFlash
  • United States: Notice 2024-77 provides guidance on Code sections 414(aa) and 402(c)(12) added by the SECURE 2.0 Act of 2022, addressing inadvertent benefit overpayments and their treatment as eligible rollover distributions, and detailing the impact on the Employee Plans Compliance Resolution System (EPCRS) as outlined in Rev. Proc. 2021-30. Comments are due by December 16, 2024. Read TaxNewsFlash

United States

  • Final regulations: Withholding under sections 3405(a) and (b) on certain payments and distributions from retirement plans
  • Notice 2024-74: Additional guidance on safe harbors for sustainable aviation fuel credit
  • Notice 2024-77: Guidance under sections 414(aa) and 402(c)(12) regarding correction of inadvertent benefit overpayments
  • Notices related to treatment of amounts paid for contraceptives under health savings accounts and high deductible health plans
  • Delaware: Changes to unclaimed property law
  • KPMG reports: South Dakota (use tax on construction equipment); Virginia (disregarded entity not subject to BPOL tax); multistate (tax-related ballot measures, manufacturing sales and use tax exemption rulings)

Read TaxNewsFlash-United States

Transfer Pricing

  • Bulgaria: Public consultation on proposed amendments to Pillar Two rules
  • France: Finance Bill 2025 includes proposed retroactive tax increases for large corporations and individuals, updates to Pillar Two rules
  • Italy: Public country-by-country reporting implemented
  • Lithuania: Public consultation on draft legislation fully implementing Pillar Two rules
  • Netherlands: 2025 Tax Plan includes proposed amendments to Pillar Two rules
  • Slovakia: Draft legislation amending Pillar Two rules submitted to Parliament

Read TaxNewsFlash-Transfer Pricing

Americas

  • Chile: Withholding on payments to U.S. residents; reporting by digital platforms; other direct and indirect tax developments
  • Dominican Republic: Tax reform bill presented to Congress
  • Mexico: Modifications to general foreign trade rules affecting IMMEX operations and VAT certifications

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Guidance on compliance approach to restructuring transactions in response to new thin capitalization rules
  • India: Long-term capital gains rate applicable to gains from depreciable assets held for more than 36 months
  • Kuwait: Guidance on requirements under tax law on disposal/destruction of fixed assets
  • Malaysia: Capital gains tax exemptions for certain group restructurings and initial public offerings
  • Saudi Arabia: Updated real estate transaction tax law

Read TaxNewsFlash-Asia Pacific

Europe

  • Bulgaria: Public consultation on proposed amendments to Pillar Two rules
  • Finland: Public consultation on proposed tax credit for investments supporting green transition
  • France: Announcement on e-invoice validation services
  • France: Finance Bill 2025 includes proposed retroactive tax increases for large corporations and individuals, updates to Pillar Two rules
  • Germany: Guidelines for complying with first phase of e-invoicing mandate
  • Italy: Import VAT is considered customs duty
  • Italy: Public country-by-country reporting implemented
  • Latvia: Temporary solidarity contribution on banks and credit institutions
  • Lithuania: Public consultation on draft legislation fully implementing Pillar Two rules
  • Netherlands: 2025 Tax Plan includes proposed amendments to Pillar Two rules
  • Poland: Character of profits of converted sole proprietorship; taxation of prizes granted to athletes; deductibility of expenses incurred by parent in support of subsidiary (Supreme Administrative Court decisions)
  • Slovakia: Draft legislation amending Pillar Two rules submitted to Parliament
  • UK: HMRC outreach to businesses in technology, media, and telecommunications sector regarding VAT compliance

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Singapore: Updated record level error codes for FATCA and CRS
  • United States: IRS updates “public key” for FATCA filing

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • U.S. BIS releases rules to modernize space-related export controls
  • U.S. BIS updates “unverified list”
  • USTR opens exclusion process for certain machinery used in domestic manufacturing
  • Vietnam-based beverage company agrees to pay $860,000 for violations of U.S. sanctions on North Korea

Read TradeNewsFlash-Trade & Customs

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