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Week in Tax: February 3 – 7, 2025

Recent tax developments from around the globe for the week of February 3 – 7, 2025

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February 10, 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 include:

  • United Kingdom: Comments are due by April 8, 2025, on supplementary draft guidance for consultation regarding the UK's Pillar Two global minimum tax rules. Additionally, HMRC released amendments to the Finance Bill 2024-2025, including updates to the UTPR rules, incorporation of OECD guidance, and changes to the qualification of permanent establishments as excluded entities. Read TaxNewsFlash
  • India: The Union Budget for FY 2025-2026 includes tax measures such as rationalizing withholding tax provisions, extending registration periods for smaller trusts, updating income tax return filing limits, and introducing a presumptive taxation scheme for nonresidents in electronic manufacturing. It also extends the tonnage tax scheme to inland vessels, aligns GST amendments with Council recommendations, and proposes various customs duty changes, while notably not altering corporate tax rates or addressing the OECD's Pillar Two global minimum tax implementation. Read TaxNewsFlash
  • United States: The Trump Administration released executive orders imposing tariffs on Canadian, Mexican, and Chinese imports due to concerns over drug trafficking and illegal immigration, with tariffs on Canadian and Mexican products postponed for 30 days. The tariffs include a 25% tariff on Canadian and Mexican products and a 10% tariff on Chinese products. Read TaxNewsFlash

United States

  • IRS practice units: Partnership liabilities, outside basis, and liquidating distributions; partial disposition of a building
  • KPMG report: Final regulations on clean hydrogen production credit and related energy credit
  • KPMG report: State and local tax changes affecting 2024 filing and payment obligations of entities taxed as partnerships
  • KPMG article: Possible comeback of section 199 domestic production activities deduction (DPAD)

Read TaxNewsFlash-United States

 

Transfer Pricing

  • India: Tax measures in budget 2025-2026
  • Italy: List of jurisdictions with transitional qualified status for Pillar Two purposes
  • Kazakhstan: Changes to transfer pricing laws included expanded reporting and disclosure requirements
  • UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
  • UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
  • UK: HMRC transfer pricing and diverted profits tax statistics for FY 2023-2024

Read TaxNewsFlash-Transfer Pricing

Asia Pacific

  • Armenia: Tax incentives for high-tech sector
  • Australia: Senate Committee report on hydrogen, critical minerals production tax incentives bill
  • India: Tax measures in budget 2025-2026
  • Kazakhstan: Changes to transfer pricing laws included expanded reporting and disclosure requirements
  • Oman: Income tax treaties signed with Cyprus, Tanzania, and Bahrain
  • Saudi Arabia: Application of withholding tax under income tax treaties
  • Saudi Arabia: Guidance on application of real estate transaction tax to “build-own-operate-transfer” contracts
  • UAE: Public consultation on e-invoicing data dictionary
  • UAE: Updated guidance on participation exemption and foreign permanent establishment exemption

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Coalition agreement of new government proposes tax reform
  • Bosnia and Herzegovina: New excise duty rates on manufactured tobacco
  • Czech Republic: Implementation of interest and royalties directive (CJEU referral)
  • Czech Republic: Legislation extending tax deductibility of donations to Ukraine passes Senate
  • Ireland: Updated guidance regarding controlled foreign company (CFC) rules
  • Italy: List of jurisdictions with transitional qualified status for Pillar Two purposes
  • Netherlands: Updated list of non-cooperative tax jurisdictions
  • OECD: Public consultation on tax incentives
  • Serbia: Amendments to e-invoicing rulebook
  • Slovakia: Second amendment to Financial Transaction Tax Act expands exemptions
  • Spain: New obligation to keep accounting records for products subject to manufacturing excise duties
  • Spain: Solidarity charge effective January 1, 2025
  • Switzerland: Final VAT guidelines on platform rules for goods
  • UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
  • UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
  • UK: HMRC transfer pricing and diverted profits tax statistics for FY 2023-2024
  • UK: Payments to settle regulatory investigation deductible; claim for cross-border group relief barred (court decisions)

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Channel Islands: Guidance on common errors in FATCA and CRS reporting (Jersey)
  • Finland: Updated FATCA and CRS FAQs
  • Spain: Updated guidance on common errors in information received via Form 289

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • USTR announces action by Mexico to resolve USMCA biotech corn dispute
  • United States announces tariffs on Canada, Mexico, and China; 30-day postponement for Canada and Mexico

Read TradeNewsFlash-Trade & Customs

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