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Week in Tax: September 30 – October 4, 2024

Recent tax developments from around the globe for the week of September 30 – October 4, 2024

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October 4, 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: KPMG LLP published a report summarizing and providing observations on the proposed corporate alternative minimum tax (CAMT) regulations that were released in September. Read TaxNewsFlash
  • United States: The IRS released Rev. Rul. 2024-23, determining that the European Energy Exchange in Germany qualifies as a "qualified board or exchange" under section 1256(g)(7)(C). This ruling applies to European Energy Exchange contracts entered into on or after November 1, 2024, including futures contracts and options described in section 1256(g)(1)(A) that are not excluded by section 1256(b)(2). Read TaxNewsFlash
  • United States: The IRS has provided tax relief for taxpayers affected by Hurricane Helene in seven states (Alabama, Florida, Georgia, North Carolina, South Carolina, Tennessee, and Virginia), storms and flooding in Illinois, and wildfires in Washington State. The affected taxpayers now have more time to file various individual and business tax returns and make tax payments. The IRS also will not impose penalties for the sale or use of dyed diesel fuel in areas affected by Hurricane Helene from September 26, 2024, until October 15, 2024. In addition, the IRS issued Notice 2024-72 to provide new relief under section 7508A for persons affected by the terroristic action in the State of Israel throughout 2023 and 2024. Read TaxNewsFlash-United States
  • Ireland: The 2025 budget includes various tax measures, such as a new participation exemption for foreign-sourced dividends, increased research and development (R&D) payment thresholds, a corporation tax deduction for listing expenses, an extension of the bank levy, and enhanced reliefs for start-ups and the audio-visual sector. Read TaxNewsFlash
  • Chile: The Tax Compliance Bill includes modifications to the general anti-avoidance rule (GAAR), transfer pricing rules, and controlled foreign companies (CFC) regulations, along with an increase in the exemption threshold for non-commercial imports and the establishment of digital platform operators as value added tax (VAT) taxpayers. Read TaxNewsFlash

United States

  • Notice 2024-72: IRS provides new relief for taxpayers affected by terroristic action in Israel
  • Notice 2024-73: Guidance on long-term, part-time employees in 403(b) retirement plans
  • Rev. Rul. 2024-23: European Energy Exchange held “qualified board or exchange”
  • U.S. Treasury statement on implementation of IRA’s clean energy provisions
  • U.S. Treasury release: No change to list of countries cooperating with international boycott
  • IRS issues list of qualified intermediary (QI) entities and branches
  • IRS Priority Guidance Plan for 2024-2025
  • IRS provides dyed diesel penalty relief due to Hurricane Helene
  • IRS provides tax relief for taxpayers in all or parts of seven states affected by Hurricane Helene
  • IRS provides tax relief for taxpayers in parts of Illinois affected by severe storms, tornadoes
  • IRS provides tax relief for taxpayers in parts of Washington State affected by wildfires
  • IRS requests comments on draft Form 7217, Partners Report of Property Distributed by a Partnership
  • KPMG article: State income tax consequences of green energy tax credit sales
  • KPMG article: Tax incentives under IRA, CHIPS Act, and U.S. FTZ Program
  • KPMG report: Exceptions under final broker digital asset reporting regulations
  • KPMG reports: California (manufacturing equipment tax credit vetoed); Massachusetts (tax amnesty); Oregon (sales factor treatment of repatriation income); Washington State (taxable digital automated services)

Read TaxNewsFlash-United States

Cooperatives

  • Notice 2024-70: Farmers, ranchers affected by drought allowed more time to replace livestock

Read TaxNewsFlash-Cooperatives

Exempt Organizations

  • IRS Priority Guidance Plan for 2024-2025—exempt organization projects
  • Notice 2024-73: Guidance on long-term, part-time employees in 403(b) retirement plans

Read TaxNewsFlash-Exempt Organizations

Transfer Pricing

  • Chile: Tax compliance bill approved by Congress includes income tax, VAT, and transfer pricing measures
  • Poland: Draft legislation implementing Pillar Two global minimum tax rules submitted to lower house of Parliament
  • KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Japan
  • KPMG article: Worldwide trends in transfer pricing

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • United States: IRS issues list of qualified intermediary (QI) entities and branches
  • OECD: User guides for XML schemas for cryptoasset reporting framework (CARF) and CRS amendments

Read TaxNewsFlash-FATCA / IGA / CRS

Africa

  • Ethiopia: New VAT rules for nonresident digital services providers
  • South Africa: Changes to corporate income tax return relating to R&D tax incentive
  • Nigeria: New withholding tax regulations effective January 1, 2025
  • Africa: Summary of tax developments (September 2024)

Read TaxNewsFlash-Africa

Americas

  • Canada: Revised draft legislation increasing capital gains inclusion rate
  • Chile: Tax compliance bill approved by Congress includes income tax, VAT, and transfer pricing measures
  • Costa Rica: New law ratifies Revised Kyoto Convention
  • Peru: Amended deadlines for recording invoices, tax authority allowed to generate purchase register
  • Trinidad and Tobago: Tax measures proposed in 2025 budget

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: First annual R&D tax incentive transparency report
  • Australia: Supplementary annual GST return for certain large taxpayers
  • Malaysia: Tax exemptions for unit trusts
  • Philippines: New law imposes VAT on cross-border provision of digital services
  • UAE: Updated executive regulation on VAT
  • KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Japan

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Overview of agreed tax measures for Flemish region
  • Cyprus: Deadline for confirmation of ultimate beneficial owner’s information is December 31, 2024
  • France: Update on 2025 finance bill
  • Germany: Ordinance on assignment of tax-related business numbers; other VAT developments
  • Ireland: Tax measures in 2025 budget
  • Netherlands: ESG proposals introduced on Budget Day
  • Poland: Draft legislation implementing Pillar Two global minimum tax rules submitted to lower house of Parliament
  • Poland: Laws introducing VAT exemption in EU, optional cash method for small enterprises passed by lower house of Parliament
  • Slovakia: Draft legislation including tax-related measures approved by Parliament
  • Slovakia: New sweetened non-alcoholic beverages tax effective January 1, 2025
  • Spain: Consultation on draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8)

Read TaxNewsFlash-Europe

Trade & Customs

  • Costa Rica: New law ratifies Revised Kyoto Convention
  • United States: BIS administrative penalties for submission of back-dated document, prohibited exports
  • United States: BIS imposes $150,000 civil penalty on California-based data storage company for antiboycott violations
  • United States: BIS publishes second quarterly update of “boycott requester list”
  • United States: DHS adds China-based steel and aspartame companies to Uyghur Forced Labor Prevention Act (UFLPA) Entity List
  • United States: Tax incentives under IRA, CHIPS Act, and U.S. FTZ Program

Read TradeNewsFlash-Trade & Customs

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