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Week in Tax: November 11 – 15, 2024

Recent tax developments from around the globe for the week of November 11 – 15, 2024

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November 15, 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).

  • Australia: The Australian Taxation Office extended the filing deadline for country-by-country (CbC) reporting entities for the year ended December 31, 2023. Local files, Master files, and CbC reports originally due December 31, 2024, are now due by January 31, 2025. Read TaxNewsFlash
  • EU: The European Commission published guidance for the updated small enterprise scheme (SME scheme), effective January 1, 2025, which includes a maximum national annual VAT exemption threshold of €85,000 and introduces a cross-border SME scheme for small enterprises with a total annual turnover not exceeding €100,000 across the EU. Read TaxNewsFlash
  • Denmark: The government's legislative program for 2024-2025 proposes tax law changes to support entrepreneurship, including tax reductions for the entrepreneurial sector such as removing dividend taxation for unlisted portfolio shares and increasing the R&D tax credit. The program also outlines changes in depreciation rules, foundation taxation, and commitments to future legislation on generational transfers, shareholder loans, and cryptoasset taxation. Read TaxNewsFlash

United States

  • KPMG report: Notable highlights from section 48D final regulations (advanced manufacturing investment credit)
  • KPMG report: Final regulations on advanced manufacturing production credit under section 45X
  • Deductibility of FDIC special assessments not limited under section 162(r)
  • IRS announces tax relief for taxpayers affected by storms and flooding in Chaves County, New Mexico
  • IRS provides tax relief for taxpayers in Cheyenne River Sioux Tribe in South Dakota affected by storms
  • IRS announces tax relief for taxpayers in Saint Regis Mohawk Tribe in New York affected by storms and flooding
  • KPMG article: IRS’s personal use of business aircraft campaign

Read TaxNewsFlash-United States

  • Senate confirms final Biden nominee to be U.S. Tax Court judge

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Armenia: Agreement on automatic exchange of country-by-country reports
  • Australia: ATO extends filing deadline for country-by-country reporting entities
  • Bahamas: Proposed Pillar Two legislation
  • Montenegro: Multilateral agreement on exchange of country-by-country reports
  • Poland: Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament
  • Slovakia: Transfer pricing for manufacturing companies (court decisions)
  • UAE: Tax guide on corporate tax returns includes transfer pricing thresholds and procedures

Read TaxNewsFlash-Transfer Pricing

Africa

  • South Africa: Conduit principle does not apply when capital gains are realized by trust

Read TaxNewsFlash-Africa

Americas

  • Bahamas: Proposed Pillar Two legislation
  • Canada: Year-end tax considerations for company owners, managers
  • Costa Rica: Electronic invoicing regulations
  • El Salvador: Guidance to identify low or no taxation jurisdictions

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: ATO extends filing deadline for country-by-country reporting entities
  • Australia: Treasury opens consultation on legislation for enhanced ownership disclosure of listed entities
  • Armenia: Agreement on automatic exchange of country-by-country reports
  • Bahrain: New income tax treaty with Guernsey; amendments to treaty with Czech Republic
  • Cambodia: Guidance on tax relief and exemptions
  • Malaysia: Income tax and real property gains tax developments
  • Maldives: Amendments to GST, tourism act, and airport fees ratified
  • UAE: Tax guide on corporate tax returns includes transfer pricing thresholds and procedures

Read TaxNewsFlash-Asia Pacific

Europe

  • Hungary: Proposed extension of retail sales tax to online marketplaces
  • Denmark: Proposed changes to tax law in legislative program
  • Slovakia: Tax collection and reporting guidelines in Financial Transactions Tax Act
  • Poland: Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament
  • Poland: Final round of consultations on national e-invoicing system; other tax developments
  • Slovakia: Transfer pricing for manufacturing companies (court decisions)
  • EU: VAT guidance on new rules for small businesses
  • Montenegro: Multilateral agreement on exchange of country-by-country reports
  • Czech Republic: New Accounting Act expected to take effect in 2026
  • Italy: New VAT treatment for supply of staff
  • Poland: Proposed legislation to enhance electromobility and reduce emissions
  • Germany: Tax policy consequences from end of governing coalition

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • United States: Scheduled maintenance for FATCA Registration System begins November 25
  • UK: Outcomes of consultation on cryptoasset reporting framework (CARF) and CRS amendments

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • EU: Combined Nomenclature for 2025
  • EU: Expansion of centralised clearance for import (CCI) system
  • U.S. life insurance company agrees to pay $178,000 for violations of sanctions on Iran

Read TradeNewsFlash-Trade & Customs

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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.

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