KPMG Week in Tax: May 19– 23, 2025

Recent tax developments from around the globe for the week of May 19– 23, 2025

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May 26, 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 House of Representatives passed the "One Big Beautiful Bill Act" (H.R. 1), which aims to make the 2017 Tax Cuts and Jobs Act provisions permanent, enhance deductions for passthrough businesses, and introduce new tax benefits while offsetting costs through measures like extending the SALT deduction limit and modifying energy tax credits. The bill, now heading to the Senate, is anticipated to undergo further changes, particularly concerning its tax provisions. Read TaxNewsFlash
  • EU: The Council Directive (EU) 2025/872, known as DAC9, establishing a framework for the exchange of Pillar Two information among EU member states, became effective on May 7, 2025. Member states are required to transpose the directive by December 31, 2025, with the first top-up tax reporting deadline set for June 30, 2026, including those delaying the implementation of the income inclusion and undertaxed profits rules. Read TaxNewsFlash
  • New Zealand: The 2025 budget introduces a 20% "investment boost" tax deduction for new qualifying business assets, alongside changes to KiwiSaver settings, which include phased increases in minimum contribution rates for employees and employers. Additional tax policy changes involve abandoning digital services tax legislation, adjusting interest deductibility for nonresidents, revising start-up company share scheme taxation, modifying foreign investment fund rules, and modernizing fringe benefit tax rules to lower compliance costs. Read TaxNewsFlash

United States

  • House passes “One Big Beautiful Bill Act”

Read TaxNewsFlash-Legislative Updates

  • Renewable electricity production inflation factors, reference prices for 2025
  • Notices of filing of petitions for addition of five substances to Superfund list
  • KPMG article: Considerations for proposed factory building expensing as domestic production incentive
  • KPMG article: Tax considerations for cryptocurrency investors

Read TaxNewsFlash-United States

 

For KPMG analysis and observations regarding sector or industry-specific provisions in the bill:

Read TaxNewsFlash

Transfer Pricing

  • Australia: Updated guidance on Pillar Two minimum tax rules
  • Bahrain: New guide on Pillar Two minimum tax rules
  • EU: DAC9 published in official journal
  • OECD: Updated transfer pricing country profiles
  • Switzerland: Public consultation on GloBE information return

Americas

  • Canada: Direct and indirect tax measures in 2025 budget (Ontario)
  • Honduras: Guidance on tax holidays, announcement of audits
  • Mexico: Third resolution of amendments to miscellaneous tax resolution for 2025

Asia Pacific

  • Australia: Tax measures in 2025 budget (Victoria)
  • Australia: Updated guidance on Pillar Two minimum tax rules
  • Bahrain: Exemption from customs duties for industrial materials
  • Bahrain: New guide on Pillar Two minimum tax rules
  • Cambodia: Issuance of notification letter for incorrect tax declarations; announcement of 2025 on-site audits
  • India: Capital gains exemption under India-Cyprus treaty granted in absence of evidence to rebut tax residency certificate (Tribunal decision)
  • Kazakhstan: Changes to calculation of excise taxes on fuels
  • New Zealand: Tax measures in 2025 budget
  • Oman: Proposed e-invoicing implementation from third quarter of 2026

Europe

  • Austria: Proposed changes to real estate transfer tax rules on share deals
  • Belgium: Mandatory disclosure rules (DAC6) upheld (Constitutional Court decision)
  • Czech Republic: Deductibility of asset repair costs; initiation of tax inspection; interest on refunds of customs duties (Supreme Administrative Court decisions)
  • Czech Republic: Draft guidance on calculating floor area for VAT purposes
  • EU: DAC9 published in official journal
  • France: Revised list of non-cooperative jurisdictions issued
  • Luxembourg: Interest-free loans treated as equity contributions, branch did not qualify as permanent establishment under Malaysia treaty (High Administrative Court decision)
  • Malta: Investor citizenship scheme violates EU law (CJEU judgment)
  • Netherlands: Draft legislation to replace “Box 3” (wealth tax) regime sent to lower house of Parliament
  • Poland: Fixed establishment for VAT purposes; insurance premiums constitute salary income; correction of invoice upon assignment of financial leasing contract (court decisions)
  • Switzerland: Public consultation on GloBE information return

FATCA / IGA / CRS

  • Barbados: CRS guidance on compliance for retirement funds
  • Saint Kitts and Nevis: CRS reporting deadline extended to July 15, 2025
  • United States: FATCA IDES testing scheduled for June 2025

Trade & Customs

  • EU adopts 17th Russia sanctions package
  • Czech Republic: Deductibility of asset repair costs; initiation of tax inspection; interest on refunds of customs duties (Supreme Administrative Court decisions)
  • Bahrain: Exemption from customs duties for industrial materials

Exempt Organizations

  • House passes “One Big Beautiful Bill Act” with provisions that would affect tax-exempts—read a KPMG report that provides initial analysis and observations regarding the provisions in the bill related to tax-exempt organizations

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