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Week in Tax: January 20 – 24, 2025

Recent tax developments from around the globe for the week of January 20 – 24, 2025

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January 27, 2025

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 this week include:

  • United States: The White House issued a memorandum indicating that previous commitments to the OECD Global Tax Deal are not binding without congressional approval and instructs the Treasury Secretary to assess foreign compliance with U.S. tax treaties and potential discriminatory tax practices against American companies. Read TaxNewsFlash
  • Australia: Treasury introduced legislation detailing the computation of the top-up tax under Pillar Two rules, effective January 1, 2024, with provisions for GloBE income, adjusted taxes, and transitional measures for MNEs. In addition, the Australian Taxation Office issued new transfer pricing guidance for private groups in the property and construction sector, focusing on demonstrating the commerciality of funding arrangements, conventional practices, and compliance obligations when receiving foreign funding. Read TaxNewsFlash
  • Mexico: “Plan Mexico" introduces tax incentives offering accelerated tax depreciation for new fixed assets acquired until September 30, 2030, and a 25% additional deduction for training and innovation expenses from 2025 to 2030. Eligibility for these incentives requires meeting specific criteria and obtaining approval from a designated evaluation committee. Read TaxNewsFlash

United States

  • White House announcement on OECD “Global Tax Deal”
  • Trump signs executive order placing hiring freeze for federal civilian employees with no expiration date for IRS
  • Daniel Werfel resigns as IRS Commissioner, Trump formally nominates William Long to replace him
  • Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations (Chief Counsel legal advice memorandum)
  • KPMG report: Regulations regarding digital content and cloud transactions
  • KPMG report: Proposed regulations on additional five highest compensated employees subject to section 162(m)
  • KPMG article: Debt workouts in commercial real estate

Read TaxNewsFlash-United States

  • Senate Finance, Foreign Relations Committees introduce Taiwan double-tax relief bill
  • Ways and Means Chairman reintroduces bill to impose additional tax if foreign jurisdiction adopts discriminatory or extraterritorial tax

Read TaxNewsFlash-Legislative Updates

Keep up to date with tax-related developments stemming from the new administration: TaxNewsFlash-Trump Tax Agenda

Transfer Pricing

  • Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
  • Australia: New transfer pricing guidance on inbound related-party funding for property and construction
  • Bahrain: Guide on entities within scope of domestic minimum top-up tax
  • Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting
  • EU: Tax priorities of Polish Presidency of the Council
  • Malaysia: Transfer pricing guidelines and audit framework for 2024
  • Romania: Clarifications on reporting form for public country-by-country disclosures
  • Slovenia: Implementation of public country-by-country reporting
  • South Africa: Legislation implementing Pillar Two global minimum tax rules enacted
  • Thailand: Law implementing Pillar Two global minimum tax rules published
  • United States: Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations (Chief Counsel legal advice memorandum)
  • United States: White House announcement on OECD “Global Tax Deal”

Read TaxNewsFlash-Transfer Pricing

Africa

  • South Africa: Legislation implementing Pillar Two global minimum tax rules enacted
  • South Sudan: Tax measures in Financial Act 2024 / 2025
  • KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated January 2025)

Read TaxNewsFlash-Africa

Americas

  • Argentina: Special procedure for refunds of PAIS tax
  • Chile: Unemployment fund management company qualifies for benefits of U.S. income tax treaty; other direct and indirect tax developments
  • Guyana: Tax proposals in 2025 budget
  • Mexico: New tax incentives under “Plan Mexico”
  • KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated January 2025)

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Consultation on miscellaneous amendments to tax laws, including GST and excise taxes
  • Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
  • Australia: New transfer pricing guidance on inbound related-party funding for property and construction
  • Bahrain: Guide on entities within scope of domestic minimum top-up tax
  • India: Amendments to foreign exchange management regulations
  • India: Grandfathering provision under tax treaty is excluded from principal purpose test
  • Malaysia: Transfer pricing guidelines and audit framework for 2024
  • Philippines: Application of VAT on digital services
  • Thailand: 2025 tax calendar
  • Thailand: Law implementing Pillar Two global minimum tax rules published
  • KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated January 2025)

Read TaxNewsFlash-Asia Pacific

Europe

  • Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting
  • EU: Tax priorities of Polish Presidency of the Council
  • Italy: Budget law introduces new VAT reverse charge mechanism for logistics sector
  • Luxembourg: Updated guidance on certificates of residence for collective investment funds
  • Poland: Deductibility of various expenses (Supreme Administrative Court decisions)
  • Poland: EU Council approves extension of split payment mechanism
  • Romania: Clarifications on reporting form for public country-by-country disclosures
  • Romania: Form for tax registration of nonresident payment service providers
  • Slovakia: Draft legislation implementing directive on tax transparency rules for cryptoasset service providers (DAC8)
  • Slovakia: Guide on new VAT rates for energy supplies effective January 1, 2025
  • Slovakia: Legislation amending motor vehicle tax rates approved by Parliament
  • Slovenia: Implementation of public country-by-country reporting
  • Spain: Dividend withholding tax in breach of EU law (CJEU judgment)
  • Spain: Filings for special taxes due in early 2025
  • UK: Costs incurred in constructing quay wall eligible for plant and machinery allowances; settlement payments to regulator not treated as non-deductible penalties (court decisions)
  • KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated January 2025)

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Finland: FATCA and CRS annual information returns for 2024 due January 31, 2025
  • France: Updated CRS technical guidance
  • Slovakia: Draft legislation implementing directive on tax transparency rules for cryptoasset service providers (DAC8)
  • United States: FATCA responsible officer certifications due July 1, 2025

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • White House announces “America First Trade Policy”
  • USTR determines that China’s targeting of maritime, logistics, and shipbuilding sectors is actionable under Section 301
  • India: Amendments to foreign exchange management regulations

Read TradeNewsFlash-Trade & Customs

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