KPMG Week in Tax: April 21 – 25, 2025

Recent tax developments from around the globe for the week of April 21 – 25, 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).

United States: The IRS LB&I division issued a memorandum reissuing interim guidance for its employees on handling taxpayer requests for advance pricing agreements (APAs), detailing the review process for APA prefiling memoranda and requests, including renewals, before acceptance into the APMA program. This guidance will be integrated into the IRS Internal Revenue Manual by October 22, 2025. Read TaxNewsFlash
Netherlands: The 2025 Spring Memorandum outlines updates to the government's budget and introduces various tax measures, including maintaining the VAT rate at 9% for the culture, media, and sports sectors; limited inflation adjustments for personal income and payroll taxes; changes to Box 3; and several other tax-related adjustments such as reductions in energy tax for households and modifications to gift and inheritance tax policies. Additionally, the memorandum addresses specific tax arrangements and proposes a one-off increase in rent allowance in 2026. Read TaxNewsFlash
South Africa: The proposed increase in the value added tax (VAT) rate, initially set to take effect on May 1, 2025, will be withdrawn. Instead, the National Treasury will introduce a revised Rates and Monetary Amounts and Amendment of Revenue Laws Bill to maintain the current 15% VAT rate, with updated draft bills expected in the coming weeks to outline adjustments to expenditure. Read TaxNewsFlash

United States

IRS guidance on review and acceptance of APA submissions
KPMG article: Impact of deregulatory actions on tax guidance
KPMG article: Impact of tariffs on transfer pricing
KPMG article: Supply chains may be strengthened with agile global mobility
KPMG report: New Form 6765, changes to research credit reporting
Michigan: Initiation of unclaimed property audit does not toll statute of limitations (Michigan Supreme Court decision)
U.S. Treasury release: No change to list of countries cooperating with international boycott

Read TaxNewsFlash-United States

Transfer Pricing

Bermuda: Updated lists of reportable jurisdictions for CbC reports, CRS information
Germany: Amended list of jurisdictions exchanging country-by-country (CbC) reports
Hong Kong: Amendments to draft legislation implementing Pillar Two global minimum tax rules
India: Transfer pricing framework in MAP agreement cannot extend to other transactions (court decision)
Israel: Guidelines on CbC report submissions for multinational enterprises
KPMG article: Brazil’s Pillar Two rules require companies to be proactive
KPMG article: Impact of tariffs on transfer pricing
Malta: Elective tax to be introduced
United States: IRS guidance on review and acceptance of APA submissions

Read TaxNewsFlash-Transfer Pricing

Africa

Libya: Statute of limitations on tax audits and collections repealed
South Africa: Withdrawal of proposed VAT increase
Uganda: Proposed changes to tax laws, including replacement of 5% DST with 15% withholding tax

Read TaxNewsFlash-Africa

Americas

Bermuda: Updated lists of reportable jurisdictions for CbC reports, CRS information
Brazil: Pillar Two rules require companies to be proactive

Read TaxNewsFlash-Americas

Asia Pacific

Hong Kong: Amendments to draft legislation implementing Pillar Two global minimum tax rules
India: Expansion of tax collection at source on specified goods
India: Mutual fund units not company shares for purposes of Singapore treaty (Tribunal decision)
India: Transfer pricing framework in MAP agreement cannot extend to other transactions (court decision)
Israel: Guidelines on CbC report submissions for multinational enterprises
Qatar: Tax return filing deadline extended to August 31, 2025
Sri Lanka: Value Added Tax (Amendment) Act No 04 of 2025 enacted
Thailand: Corporate income tax exemption and reduced individual income tax for highly skilled Thai professionals
UAE: New application for treatment of family foundations as unincorporated partnerships; guidance on requests for extended deadline for tax assessment review or reconsideration

Read TaxNewsFlash-Asia Pacific

Europe

Austria: Limitation on application of prohibition on deducting intragroup interest and license fees (Federal Finance Court decisions); other recent tax developments
Germany: Building contract modifications increase real estate transfer tax; special depreciation allowance for new residential construction denied (court decisions)
Germany: Amended list of jurisdictions exchanging country-by-country (CbC) reports
Italy: Guidance for fiscal representatives on eligibility criteria and submission of guarantees
Malta: Elective tax to be introduced
Malta: Large taxpayer office established
Netherlands: Tax measures in 2025 Spring Memorandum sent to Parliament

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

Bermuda: Updated lists of reportable jurisdictions for CbC reports, CRS information

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

KPMG article: Impact of tariffs on transfer pricing
KPMG article: Supply chains may be strengthened with agile global mobility
U.S. BIS requests comments on Section 232 investigations of imports of processed critical minerals and imports of trucks
U.S. CBP implements new duties on Chinese imports

Read TradeNewsFlash-Trade & Customs

Other publications

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

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