Week in Tax: December 9 – 13, 2024

• Final and proposed regulations: Taxable income or loss and foreign currency gain or loss with respect to a QBU
• Notice 2025-2: Penalty relief for partnerships to provide complete Forms 8308 for section 751(a) exchanges
• Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
• U.S. Tax Court: Taxpayer entitled to section 199 deductions
• IRS provides new tax penalty relief for Maui wildfire victims
• Louisiana: Several tax bills approved
• KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”

Read TaxNewsFlash-United States

• Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
• Australia: Updated guidance on public country-by-country reporting
• EU: ECOFIN report on various tax initiatives
• EU: Final public country-by-country reporting forms published
• France: Guidance on Pillar Two global minimum tax filing and notification obligations
• Malaysia: Guidance on Pillar Two global minimum tax
• Nigeria: Guidelines on advance pricing agreements
• KPMG article: OECD advance pricing agreement statistics for 2023

Read TaxNewsFlash-Transfer Pricing

• Nigeria: Guidelines on advance pricing agreements
• South Africa: Discussion document on taxation of collective investment schemes

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• Brazil: Further updates to electronic invoicing due to tax reform
• Chile: Draft guidance clarifying VAT obligations of nonresident sellers
• Costa Rica: Miscellaneous stamp tax reforms
• Peru: Draft regulation implementing VAT compliance obligations for nonresident digital services providers
• Peru: Tax identification registration requirements for nonresident providers of remote gambling and sports betting services

Read TaxNewsFlash-Americas

• Australia: Consultation on updated draft ruling on application of “capital gains tax event K6”
• Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
• Australia: Proposed first-home buyer duty relief and general practitioner payroll tax exemption (Queensland)
• Australia: Taxpayer alerts on early-stage investor tax offset scheme, Division 7A circumvention arrangements
• Australia: Updated guidance on public country-by-country reporting
• India: New group of taxpayers required to report invoices within 30 days
• Indonesia: Guidance on tax treatment of joint operations
• Malaysia: Guidance on Pillar Two global minimum tax
• Malaysia: Tax developments summary (December 2024)
• New Zealand: Consultation on proposed changes to foreign investment fund rules for immigrating individuals

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• Austria: Input VAT deduction of import VAT for leased machinery (Federal Finance Court decision); other recent direct and indirect tax developments
• Belgium: Transitional rules for home electricity cost reimbursement
• Czech Republic: Denial of mineral oil excise tax refund upheld (Supreme Administrative Court decision)
• Czech Republic: Requirements for December VAT return
• Denmark: Digital bookkeeping system capable of handling electronic invoices required as of January 1, 2025
• EU: Council adopts new rules for harmonized withholding tax procedures (FASTER Directive)
• EU: ECOFIN report on various tax initiatives
• EU: European Court of Auditors report on ATAD, mandatory disclosure rules (DAC6), and tax dispute resolution directive (TDRD)
• EU: Final public country-by-country reporting forms published
• EU: New directive to introduce electronic tax certificate for VAT exemptions
• France: Guidance on Pillar Two global minimum tax filing and notification obligations
• Greece: New law introduces tax incentives for innovation and corporate transformations
• Italy: New VAT place of supply rules for virtual events
• Netherlands: Guidance on application of new framework for determining tax characterization of foreign legal forms
• Norway: Updated standard audit file for tax reporting standard
• Romania: Compatibility of windfall tax on energy producers with EU law (CJEU referral)
• Slovakia: Amendment to Financial Transactions Tax Act approved by Parliament
• Slovakia: Amendment to VAT law approved by Parliament
• Spain: VAT notices due by end of year

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• Brazil: Consultation deadline on draft guidance implementing cryptoasset reporting extended
• Channel Islands: Consultation on cryptoasset reporting framework (CARF) and CRS amendments (Jersey)
• Liechtenstein: Registration of trustee-documented trusts for CRS purposes
• United States: Scheduled maintenance for FATCA Registration System begins December 30

Read TaxNewsFlash-FATCA / IGA / CRS

• KPMG report: Free trade agreement finalized between EU and Mercosur
• U.S. BIS adds eight entities to EAR Entity List
• U.S. BIS renews temporary denial orders for two Russian airlines
• U.S. OFAC reaches settlement with Minnesota-based company over violation of sanctions on Cuba and Iran
• USTR increases Section 301 tariffs for Chinese imports of tungsten products, solar wafers, and polysilicon
• USTR initiates Section 301 investigation of Nicaragua’s labor and human rights practices

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

• BEPS
• Indirect Tax
• Digital Economy
• Tax Controversy