Week in Tax: November 4 – 8, 2024

• KPMG report: Election results, preliminary observations regarding effect on future tax agenda
• KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations
• KPMG article: Subchapter K changes as possible revenue raisers in addressing 2025 “Tax Cliff”
• Extension of certain timeframes for employee benefit plans and participants affected by Hurricane Helene, Tropical Storm Helene, or Hurricane Milton
• IRS grants tax relief for taxpayers in Havasupai Tribe in Arizona affected by flooding

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• Tax-exempt organizations without direct pay registration number for clean energy credits again urged to contact IRS

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• Chile: Amendments to transfer pricing rules
• Hong Kong: Outcomes from Pillar Two consultation
• Hungary: Reporting obligation of taxpayers subject to global minimum tax
• Israel: Proposed "Green Track" for R&D centers
• Italy: Guidance on substance based income exclusion (SBIE) provisions under Pillar Two rules
• Luxembourg: Revised draft law amending Pillar Two law
• Netherlands: Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives
• Norway: Budget would introduce undertaxed profits rule (UTPR) from 2025
• Poland: Proposed reforms to tax incentives system in light of Pillar Two
• Portugal: Bill implementing Pillar Two passed by Parliament

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• Kenya: Supreme Court holds Finance Act, 2023 constitutional, overturns Court of Appeal
• South Africa: Proposal to apply official rate of interest rule to loans to trusts

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• Brazil: Updated layout for VAT and excise tax returns
• Chile: Amendments to transfer pricing rules
• Colombia: E-invoice requirements for tax deductions in credit operations
• Colombia: Obligation to generate electronic payroll payment support document for payments in kind
• Costa Rica: Automatic exchange of information for sellers on digital platforms
• Panama: Tax amnesty for payment of national taxes

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• Hong Kong: Outcomes from Pillar Two consultation
• India: Nonrefundable advance maintenance fees taxable in year of receipt
• Israel: Proposed "Green Track" for R&D centers
• New Zealand: Trade agreement with GCC (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and UAE)
• Oman: Tax treaties to avoid double taxation signed with Luxembourg and Estonia
• Philippines: Bill allowing nonresident tourists to apply for VAT refunds approved by Senate
• Saudi Arabia: E-invoicing requirement extended to 17th group of taxpayers from July 31, 2025
• UAE: Corporate tax guide on tax residency and tax residency certificate

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• Croatia: Establishment of new company to maintain benefit of VAT exemption scheme for small enterprises constitutes abusive practice
• Cyprus: Zero VAT rate on certain goods extended to December 31, 2025
• Estonia: Proposed expansion of scope of security tax and increased VAT rate, amendments to taxation of income earned through business accounts
• EU: Member states agree on VAT in the digital age (ViDA) package
• Germany: Relief for VAT-related obligations; other VAT developments
• Hungary: Reporting obligation of taxpayers subject to global minimum tax
• Italy: Guidance on substance based income exclusion (SBIE) provisions under Pillar Two rules
• Latvia: Updated list of low-tax or tax-free jurisdictions
• Luxembourg and Estonia: Tax treaties to avoid double taxation signed with Oman
• Luxembourg: Revised draft law amending Pillar Two law
• Netherlands: Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives
• Netherlands: Time to restructure to a “repurchase fund” extended for one year
• Netherlands: Withholding tax on dividends received by UK company potentially impermissible under EU law (CJEU judgment)
• Norway: Budget would introduce undertaxed profits rule (UTPR) from 2025
• Norway: Carbon border adjustment mechanism (CBAM) for imports from 2026
• Poland: Authority of head of tax office, English version of tax treaties controls, deduction for unduly paid VAT, taxation of employer-paid insurance premiums
• Poland: Introduction of optional cash method for small enterprises, proposed changes to postponement of mandatory e-invoicing system
• Poland: Proposed reforms to tax incentives system in light of Pillar Two
• Portugal: Bill implementing Pillar Two passed by Parliament
• Spain: Guidance on required specifications for electronic invoicing systems
• Spain: Special tax regime of the Balearic Islands; relief for taxpayers affected by flooding
• UK: Unallowable purpose rule for loans, small and medium-sized enterprise R&D regime, stamp duty land tax payment and filing obligations

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• New Zealand: Trade agreement with GCC (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and UAE)
• Norway: Carbon border adjustment mechanism (CBAM) for imports from 2026
• United States: BIS renews temporary denial of export privileges of Russian airline for one year
• United States: DHS adds China-based textile companies to Uyghur Forced Labor Prevention Act (UFLPA) Entity List

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The items described above are also reported as editions of TaxNewsFlash:

• BEPS
• Indirect Tax
• Digital Economy
• Tax Controversy