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KPMG Week in Tax: March 31 – April 4, 2025

Recent tax developments from around the globe for the week of March 31 – April 4, 2025

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April 7, 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: President Trump signed an executive order to impose a 10% tariff on all countries starting April 5, 2025, with higher reciprocal tariffs on nations with significant U.S. trade deficits beginning April 9, 2025, under the International Emergency Economic Powers Act of 1977. Certain goods already subject to Section 232 tariffs are exempt, and the tariffs will remain until the trade deficit concerns are addressed, with potential adjustments based on trading partners' actions. Read TradeNewsFlash
  • Japan: The National Diet approved the 2025 tax reform bills, which include changes to corporate tax, measures for defense funding, leasing taxation, reduced tax rates for small and medium-sized companies, international tax regulations such as a global minimum tax and controlled foreign company (CFC) regime, consumption tax on leasing, individual tax reliefs, and a preservation system for electronic transaction records. Read TaxNewsFlash
  • UK: The Finance Act 2025, which received Royal Assent, introduces changes to the UK Pillar Two rules, including the implementation of an undertaxed profits rule (UTPR) for accounting periods starting on or after December 31, 2024, and the introduction of transitional UTPR and country-by-country reporting safe harbors. The Finance Act incorporates OECD guidance and applies most provisions retroactively for financial years beginning on or after December 31, 2023, with some provisions applicable from December 31, 2024, unless retroactive application is elected. Read TaxNewsFlash

United States

  • Notice 2025-19: Request for recommendations for IRS 2025-2026 Priority Guidance Plan
  • Notice of filing of petition for addition of polyisobutylene to Superfund list
  • Notices of filing of petitions for addition of 16 substances to Superfund list
  • IRS practice units: Foreign currency translation; reduced foreign taxes under treaty provisions
  • IRS practice units: International tax issues including branch profits tax, hedge fund basics, and BEAT

Read TaxNewsFlash-United States


Legislative Updates

  • Senate Budget Committee releases 2025 budget resolution
  • House passes two disaster-related tax bills and four bills aimed at improving tax administration

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Bulgaria: Amendments to Pillar Two law enacted
  • EU: Commissioner outlines EC tax priorities at 2025 EU Tax Symposium
  • Finland: Guidance on Pillar Two global minimum tax
  • Germany: Increased tax audit scrutiny on intra-group data centers
  • Japan: 2025 tax reform bills, including Pillar Two rules, passed by Parliament
  • KPMG report: Overview of topics and workstreams discussed at recent meeting of UN Tax Committee
  • Qatar: Introduction of Pillar Two global minimum tax rules
  • Spain: Regulations under Pillar Two global minimum tax law
  • UK: 2025 Finance Act enacted, includes changes to UK Pillar Two rules
  • UK: Consultation on new advance tax clearance service for large innovative investment projects following Spring Statement
  • UK: Lists of jurisdictions with qualifying income inclusion rules and domestic top-up taxes under Pillar Two rules

Read TaxNewsFlash-Transfer Pricing

Americas

  • Canada: Elimination of federal fuel charge effective April 1, 2025
  • Colombia: Application terms for participation in 2025 program providing tax benefits for contributions to arts, culture, and heritage projects

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Changes to ATO top 500 program
  • Australia: Guidance on debt deduction creation rules
  • Australia: Proposed additional “affordable dwelling” requirements under build to rent scheme
  • Australia: “Rollover” relief applied to “top hatting” reorganization (Full Federal Court decision)
  • Hong Kong: Guide to 2024-2025 profits tax filing
  • Japan: 2025 tax reform bills, including Pillar Two rules, passed by Parliament
  • New Zealand: Consultation on reform of fringe benefit tax rules
  • Qatar: Introduction of Pillar Two global minimum tax rules
  • Sri Lanka: Guidance on advance income tax procedures

Read TaxNewsFlash-Asia Pacific

Europe

  • Bulgaria: Amendments to Pillar Two law enacted
  • Cyprus: Extended deadline for non-taxation election on property leasing
  • Cyprus: Tax card for 2025
  • EU: Commissioner outlines EC tax priorities at 2025 EU Tax Symposium
  • EU: Tax aspects of European Commission communication on savings and investments union
  • Finland: Guidance on Pillar Two global minimum tax
  • Germany: Final guidance on interest deduction limitation rules
  • Germany: Increased tax audit scrutiny on intra-group data centers
  • Germany: Liability for incorrect tax statements (Federal Tax Court decision); other VAT developments
  • Italy: Imposition of IRAP on dividends may be inconsistent with PSD depending on nature of tax (CJEU Advocate General opinion)
  • Netherlands: Capital loss upon liquidation of subsidiary allowed (Supreme Court decision)
  • Poland: Consultation on draft regulation on maintaining tax revenue and expense ledgers
  • Poland: Time limit for bad debt relief inconsistent with VAT directive; legal activities of family foundations; taxation of free transmission easement; real estate tax issues
  • Slovakia: Input VAT deduction limited to 50% on purchase of motor vehicles and motorcycles
  • Spain: Amendments to real estate transfer tax and stamp duty (Catalonia)
  • Spain: Regulations under Pillar Two global minimum tax law
  • UK: 2025 Finance Act enacted, includes changes to UK Pillar Two rules
  • UK: Consultation on new advance tax clearance service for large innovative investment projects following Spring Statement
  • UK: Consultation on proposed improvements to advance tax clearance process for R&D claims following Spring Statement
  • UK: Costs for preliminary windfarm studies qualified as capital expenditures (Court of Appeal decision)
  • UK: Lists of jurisdictions with qualifying income inclusion rules and domestic top-up taxes under Pillar Two rules

Read TaxNewsFlash-Europe

Trade & Customs

  • White House announces 10% tariff on all countries, effective April 5, 2025
  • U.S. CBP guidance on reciprocal tariffs with April 5 effective date
  • White House announces end of duty-free de minimis treatment for low-value Chinese imports
  • U.S. CBP issues withhold release order on Korean salt farm
  • U.S. BIS issues temporary denial orders against Russian airline and company in Kenya

Read TradeNewsFlash-Trade & Customs

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