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Week in Tax: October 21 – 25, 2024

Recent tax developments from around the globe for the week of October 21 – 25, 2024

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October 25, 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. Treasury Department and IRS released final regulations for the advanced manufacturing production credit under section 45X and the advanced manufacturing investment credit under section 48D, both established to incentivize U.S. production of eligible components and semiconductors. Additionally, proposed regulations for the energy efficient home improvement credit under section 25C provide guidance on qualifying property, credit calculations, and manufacturer requirements.
  • Austria: Only one constituent entity is designated as the Pillar Two taxpayer responsible for submitting declarations and paying top-up tax. If multiple entities exist, the “top” entity or the most economically significant one is chosen. The ultimate parent entity (UPE) can appoint an alternative entity as the taxpayer. For calendar year taxpayers, this appointment must be filed by December 31, 2024, with proof uploaded to FinanzOnline.
  • Italy: A proposal to remove the revenue thresholds for purposes of the Italian digital service tax (DST) will be discussed in Parliament over the coming weeks.
  • Malaysia: The 2025 budget focuses on revising the sales and service tax regime, increasing sales tax on non-essential items, expanding service tax to commercial services between businesses, and phasing in higher excise duties on sugar-sweetened beverages. Additionally, it introduces direct tax proposals including a 2% dividend tax on high local dividend income, extended personal income tax reliefs, and new investment incentives.

United States

  • Final regulations: Guidance on advanced manufacturing production credit under section 45X
  • Final regulations: Advanced manufacturing investment credit rules under sections 48D and 50
  • Proposed regulations and Rev. Proc. 2024-31: Guidance on energy efficient home improvement credit under section 25C
  • Proposed regulations: Amendments to coverage of certain preventive services under Affordable Care Act
  • Rev. Proc. 2024-40: Inflation adjustments for 2025, individual taxpayers
  • IRS provides tax relief to taxpayers affected by floods in Juneau, Alaska
  • KPMG reports: California (bad debt deductions for sales and use tax purposes); Ohio (debit authorization services not subject to sales tax); Washington State (B&O apportionable services reconciliation)

Read TaxNewsFlash-United States

  • Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023

Read TaxNewsFlash-Exempt Organizations

Transfer Pricing

  • Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024
  • Belgium: Public consultation on draft tax return under Pillar Two rules
  • OECD: Developments in international tax reform—digitalization of the economy and BEPS minimum standards
  • KPMG article: Potential effects of artificial intelligence on transfer pricing

Read TaxNewsFlash-Transfer Pricing

Americas

  • Argentina: Creation of new federal collection agency (ARCA)
  • Argentina: Income tax treaty with China ratified
  • Bolivia: “Twelfth group of taxpayers” to implement online billing modality
  • Canada: Surtax relief measures for importers of Chinese goods
  • Dominican Republic: Tax reform bill withdrawn
  • Mexico: New obligations for crowdfunding platforms to withhold income tax and VAT
  • Mexico: New VAT withholding requirement for platforms facilitating the sales of goods for nonresidents
  • Mexico: Tax authority clarifies definition of digital intermediation services

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: New South Wales (duty, land tax treatment of corporate collective investment vehicles); Victoria (off-the-plan stamp duty concession)
  • Cambodia: Guidance covering fiscal obligations for real estate leases, cessation of business, tax relief for airlines
  • Cambodia: Tax, accounting, labor, and regulatory compliance reminders for 2024-2025
  • Hong Kong: Draft legislation granting tax deduction for lease reinstatement costs, removing time limit for claiming building allowances
  • Korea: Royalties for use of unregistered patents subject to tax under U.S. treaty (Tax Tribunal decision)
  • Malaysia: Indirect tax proposals in 2025 budget
  • Malaysia: Overview of direct tax measures in 2025 budget

Read TaxNewsFlash-Asia Pacific

Europe

  • Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024
  • Belgium: Public consultation on draft tax return under Pillar Two rules
  • Cyprus: Deadline for 2023 individual income tax returns is October 31, 2024
  • Finland: Luxembourg SCS fund comparable under EU law to Finnish contractual-based special investment fund (Administrative Court decision)
  • France: Update on introduction of mandatory e-invoicing
  • Italy: Proposal to remove digital service tax revenue thresholds
  • Norway: Swedish convertible bonds classified as derivative covered by exemption method (Tax Appeals Board decision)
  • UK: Predictions for the Autumn Budget 2024

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Singapore: Updated guidance on FATCA and CRS return
  • United States: IRS issuing manual IDES notifications through October 31
  • KPMG report: New XML schemas for cryptoasset reporting framework (CARF) and CRS amendments

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Canada: Surtax relief measures for importers of Chinese goods
  • U.S. BIS amends Export Administration Regulations (EAR) by revising entity list
  • Updated price cap guidance for global maritime oil industry

Read TradeNewsFlash-Trade & Customs

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