Week in Tax: March 3 – 7, 2025

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

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March 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 States: The White House announced adjustments to tariffs on imports from Canada and Mexico to align with the automotive supply chain structure and minimize disruption to the U.S. automotive industry, including a 25% tariff on non-USMCA compliant goods, and a 10% tariff on certain energy products and potash from Canada and Mexico. In other tariff news, Canada and China requested dispute consultations with the United States at the World Trade Organizations concerning new U.S. tariff measures. Read TradeNewsFlash
  • UAE: The Ministry of Finance has released FAQs about its Pillar Two domestic minimum top-up tax (DMTT), which is expected to achieve "qualified" status under the OECD peer review process due to its alignment with global anti-base erosion rules. While the UAE has opted not to implement the income inclusion rule (IIR) or a controlled foreign company regime at this time, it will monitor the DMTT's effectiveness and may consider future changes, ensuring compliance with local financial standards and allowing qualifying free zone persons to comply if thresholds are met. Read TaxNewsFlash
  • Serbia: The Ministry of Finance has issued a rulebook on arm’s length interest rates for 2025, effective March 8, 2025, allowing taxpayers to choose between using prescribed interest rates or applying OECD-based methods for determining arm’s length interest, with the requirement that the chosen method be consistently applied to all intercompany loans. The rulebook specifies different interest rates for long-term and short-term borrowings for non-finance entities and a single rate for banks and finance leasing companies, except for RSD denominated loans, which have separate rates for short-term and long-term loans. Read TaxNewsFlash

United States

  • Notice 2025-16: Housing expense limit adjustments, foreign locations for 2025
  • Rev. Rul. 2025-7: Interest rates, tax underpayments and overpayments remain the same for second quarter 2025
  • Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions
  • KPMG report: Forms 1042 and 1042-S reporting updates

Read TaxNewsFlash-United States

  • President Trump addresses TCJA and other tax proposals in speech to Congress

Read TaxNewsFlash-Trump Tax Agenda

Transfer Pricing

  • Australia: Tax authority statement regarding Federal Court decision that taxpayer entitled to interest deductions with respect to foreign related-party financing
  • Cameroon: Guidelines for local country-by-country declarations
  • Indonesia: Implementation of global minimum tax
  • Serbia: Rulebook on arm’s length interest rates for 2025
  • UAE: FAQs on Pillar Two domestic minimum top-up tax

Read TaxNewsFlash-Transfer Pricing

Africa

  • Cameroon: Amendments to business license duties, synthetic tax
  • Cameroon: Guidelines for local country-by-country declarations
  • Mozambique: Tax proposals announced by president in inauguration speech
  • Senegal: Mandatory electronic invoicing proposed in 2025 Finance Bill
  • Tunisia: Clarification on tax regime for communitarian companies

Read TaxNewsFlash-Africa

Americas

  • Argentina: Suspension of withholding tax and VAT on certain imported goods ended March 1
  • Belize: Tax administration announces upcoming e-invoicing mandate
  • Canada: Tax measures in 2025 budget include real estate tax, film-related changes (British Columbia)
  • Colombia: Draft guidance modifying e-invoicing requirements
  • Costa Rica: Updated tax brackets for moveable property for 2026; threshold for real estate tax exemption for 2025

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Car park exempt from fringe benefits tax due to operational purpose and fee structure (Federal Court decision)
  • Australia: Non-compliant small businesses to shift to monthly GST reporting
  • Australia: Proposed two-year freeze on draught beer excise indexation
  • Australia: Tax authority statement regarding Federal Court decision that taxpayer entitled to interest deductions with respect to foreign related-party financing
  • Australia: Termination of taxpayer’s gaming licenses did not create financial arrangement subject to TOFA rules (Federal Court decision)
  • Azerbaijan: Reduction in branch profit tax rate; VAT exemption for transfers of land use rights; tax incentives for green projects
  • Bahrain: Updated VAT manuals
  • Cambodia: Updated guidance on income tax, various indirect taxes
  • India: Payments for bareboat chartering of dredger not taxable as royalties under Belgium treaty (Tribunal decision)
  • India: Two-year limitation period for nonresidents to submit refund claims not authorized under statute (High Court decision)
  • Indonesia: Implementation of global minimum tax
  • Japan: Additional 2025 tax reform proposals concern basic deduction
  • New Zealand: Amendments to omnibus August tax bill
  • Philippines: Expansion of e-invoicing resumed
  • Saudi Arabia: E-invoicing requirement extended to 21st group of taxpayers from November 30, 2025
  • Thailand: Revised input tax allocation for registered operators
  • Turkey: Increased VAT refund limit for 2025
  • Turkey: Increased withholding tax rates on income from certain financial instruments
  • UAE: FAQs on Pillar Two domestic minimum top-up tax

Read TaxNewsFlash-Asia Pacific

Europe

  • Czech Republic: Taxpayer failed to prove actual amount of nondeductible indirect shareholding expenses (Supreme Administrative Court decision)
  • Denmark: Computational adjustments for foreign withholding tax relief were subject to extended reassessment deadline for controlled transactions (Supreme Court decision)
  • EU: European Parliament approves VAT in the digital age (ViDA) package
  • Germany: Taxpayer not entitled to apply margin-scheme taxation; other VAT developments
  • Greece: Streamlined process for reporting withheld taxes and digital transactions fees; incentives for audiovisual projects
  • Greece: Taxpayer funded by EU subsidies entitled to input VAT deductions; property tax exemption unavailable because indirect ownership could not be verified (Supreme Administrative Court decisions)
  • Hungary: New place of supply rules for online events; changes to scope of environmental protection product fee
  • KPMG report: Shipping and offshore tax update (March 2025)
  • Moldova: Guidance on various direct and indirect tax issues; consultation on amendments to VAT refund requirements; changes to tax invoice requirements
  • Netherlands: Guidance on tax consequences of asset transfers during liquidation within fiscal unity, amendments to definition of exempt investment institution
  • Netherlands: Updated property transfer tax decree extends exemption to acquisitions of real estate companies
  • Poland: Extension of reverse charge VAT on exchange transactions related to gas, energy, CO2 allowances
  • Poland: No joint and several VAT liability for third parties not part of legal proceedings (CJEU judgment)
  • Poland: Tax exemption limited to externally managed investment funds incompatible with EU law (CJEU judgment)
  • Serbia: Rulebook on arm’s length interest rates for 2025
  • Sweden: Proposed increase to property tax for wind turbines; deductions for fictitious tax under income tax treaty with Luxembourg
  • Sweden: Support services are not unique, market value must be determined based on comparables (CJEU Advocate General opinion)
  • UK: Final regulations implementing new reserved investor fund

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Liechtenstein: Updated CRS guidance for AEOI
  • Liechtenstein: Updated FATCA reporting technical guidance
  • Saint Kitts and Nevis: Guidance on process to deregister from AEOI portal
  • United States: Forms 1042 and 1042-S reporting updates

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Canada and China request WTO dispute consultations over U.S. tariff measures
  • EU updates guidance on preferential rules of origin
  • KPMG report: Shipping and offshore tax update (March 2025)
  • U.S. BIS modifies HTSUS to conform with 25% tariffs on aluminum and steel imports
  • U.S. tariffs on Canada and Mexico take effect March 4; duty-free de minimis treatment allowed
  • United States increases tariffs on Chinese imports to 20%
  • United States initiates Section 232 investigation into timber and lumber imports
  • USTR presents President Trump’s 2025 trade policy agenda to Congress
  • White House announces adjustments to tariffs on imports from Canada and Mexico

Read TradeNewsFlash-Trade & Customs

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