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Week in Tax: December 23, 2024 – January 3, 2025

Recent tax developments from around the globe for the week of December 23, 2024 – January 3, 2025

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December 23, 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). Highlights these two weeks include:

  • United States: Treasury and the IRS issued final regulations implementing the credit for production of clean hydrogen under section 45V and the associated energy credit under section 48(a)(15), as established and amended by the Inflation Reduction Act of 2022. Read TaxNewsFlash
  • United States: Treasury and the IRS issued final regulations requiring non-custodial brokers that regularly provide services effectuating certain digital asset sales and exchanges to file information returns and furnish payee statements reporting gross proceeds in such transactions occurring on or after January 1, 2027. The IRS also issued Notice 2025-3 providing transitional relief from penalties for such brokers who fail to satisfy those requirements provided they make a good faith effort to comply. Read TaxNewsFlash
  • Japan: The ruling governing coalition agreed to an outline of tax reform proposals for 2025, including introduction of undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT) in line with Pillar Two global minimum tax regime. Read TaxNewsFlash
  • Peru: The Peruvian tax administration adopted the previously issued draft regulation implementing new value added tax (VAT) compliance obligations for nonresident digital services providers, effective January 1, 2025. Read TaxNewsFlash

United States

  • Final regulations: Clean hydrogen production credit and related energy credit
  • IRS annual revenue procedures for 2025
  • U.S. Treasury release: No change to list of countries cooperating with international boycott
  • Proposed regulations and Rev. Proc. 2025-9: Excise tax under section 5000D on designated drugs
  • Announcement 2025-5: Partial suspension by mutual agreement of income tax treaty with USSR as it relates to Belarus
  • Notice 2025-7: Temporary relief for making adequate identification of units of digital assets held in broker’s custody
  • Final and proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity
  • Final regulations: Treatment of tax-exempt bonds as retired
  • Information reporting by non-custodial brokers of digital asset transactions
  • Technical corrections to proposed regulations on corporate alternative minimum tax (CAMT)
  • Proposed regulations withdrawn: Rescission of “moral exemption rule” to coverage of certain contraceptive services under Affordable Care Act
  • U.S. Tax Court: Active partners’ income subject to self-employment tax

Read TaxNewsFlash-United States

Transfer Pricing

  • Hong Kong: Draft legislation implementing Pillar Two global minimum tax rules
  • Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
  • Japan: Outline of 2025 tax reform proposals, including new Pillar Two rules
  • Portugal: Relatedness determined on transaction date; improper rejection of transfer pricing method (Supreme Administrative Court decisions)

Read TaxNewsFlash-Transfer Pricing

Americas

  • Argentina: Rate and maximum amounts of statistics fee on certain imports
  • Argentina: Suspension of withholding tax and VAT on certain imported goods
  • Martinique: Agreement to review various fiscal measures, including VAT and customs exemptions for certain products
  • Mexico: Amendments to city tax code for 2025 (Mexico City)
  • Peru: Regulation implementing VAT compliance obligations for nonresident digital services providers
  • Venezuela: Regulations regarding use of digital media for issuance of invoices

Read TaxNewsFlash-Americas

Asia Pacific

  • China: VAT law enacted
  • Hong Kong: Draft legislation implementing company re-domiciliation regime
  • Hong Kong: Draft legislation implementing Pillar Two global minimum tax rules
  • Japan: Outline of 2025 tax reform proposals, including new Pillar Two rules
  • Oman: Tax treaties with Luxembourg and Estonia ratified
  • Oman: Income tax treaty with Ireland ratified
  • Pakistan: Income Tax Amendment Ordinance, 2024 increases tax rate for banking sector
  • Taiwan: Guidance on income tax withholding, non-withholding tax statements, tax calculation for foreign enterprises
  • Taiwan: Recent guidance on income tax withholding
  • Turkey: Amended electronic invoice and document requirements for various sectors
  • Turkey: Clarified withholding tax requirements for payments from electronic commerce intermediaries to service providers
  • Turkey: Reduced exemption rate for corporations for gains derived from sales of certain assets
  • Turkey: Updated guide on mutual agreement procedures under income tax treaties
  • Uzbekistan: Proposed tax measures in 2025-2027 budget
  • Uzbekistan: Tax incentives for businesses that maintain high sustainability rating
  • Vietnam: Reduced VAT rate on certain goods and services

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Guidance on new controlled foreign company rules
  • Ireland: Income tax treaty with Oman ratified
  • Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
  • Luxembourg and Estonia: Tax treaties with Oman ratified
  • Norway: Proposed amendments to exit tax rules secure sufficient support in Parliament
  • Portugal: Direct and indirect tax measures in 2025 budget bill
  • Portugal: Relatedness determined on transaction date; improper rejection of transfer pricing method (Supreme Administrative Court decisions)
  • Serbia: Law on electronic goods delivery notes enacted
  • Spain: New tax on financial institutions, new excise duty on tobacco products, measures to combat VAT fraud with respect to fuels

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Cayman Islands: Updates on upcoming CRS comprehensive reviews
  • British Virgin Islands: Updates to CRS compliance procedures for 2025

Read TaxNewsFlash-FATCA / IGA / CRS

Exempt Organizations

  • IRS annual revenue procedures for 2025
  • Technical correction to proposed regulations on corporate alternative minimum tax (CAMT)

Read TaxNewsFlash-Exempt Organizations

Trade & Customs

  • U.S. BIS adds 13 entities to EAR Entity List
  • U.S. OFAC issues Russia-related general license and FAQ
  • New York-based company agrees to pay $180,000 for unlicensed shipments of electronics manufacturing materials to Russia
  • USTR initiates Section 301 investigation into China's semiconductor industry practices

Read TradeNewsFlash-Trade & Customs

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