KPMG Week in Tax: June 16 – 20, 2025

Recent tax developments from around the globe for the week of June 16 – 20, 2025

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June 23, 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 Senate Finance Committee released legislative text of the tax title to be included in the Senate’s version of the budget reconciliation bill. Like H.R. 1 (the “One Big Beautiful Bill Act”) passed by the House of Representatives on May 22, 2025, the Senate’s version of the bill would generally make the tax provisions of the 2017 Tax Cuts and Jobs Act (TCJA) permanent, and also introduce several new tax benefits proposed by the president during the campaign and a host of revenue-raising provisions. The Senate bill does make several modifications to the House bill, however. Read TaxNewsFlash
  • France: The French Conseil d’État referred a priority question of constitutionality to the French Constitutional Court regarding the French digital services tax (DST), enacted in 2019—the first time the French DST has been submitted to constitutional review. Read TaxNewsFlash
  • Vietnam: The National Assembly of Vietnam passed legislation that changes the taxation of capital gains recognized by nonresident shareholders on shares in non-public joint stock companies or limited liability companies in Vietnam—effective October 1, 2025. Read TaxNewsFlash

United States

  • U.S. Tax Court: Taxpayer not required to treat payment as a result of failed merger as capital loss under section 1234A(1)
  • IRS announces improvements to pre-filing agreement program
  • KPMG article: Evaluating revised retaliatory measures in House bill
  • KPMG report: Section 83(b) elections

Read TaxNewsFlash-United States

  • Overview of Senate tax measures for budget reconciliation
  • Finance Committee releases tax title for Senate version of budget reconciliation bill

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Australia: Further guidance on public country-by-country reporting
  • Netherlands: Report on international tax rulings, including APAs, requested during 2024
  • Spain: Consultation on draft Pillar Two forms

FATCA / IGA / CRS

  • Bahamas: Updated FATCA / CRS reporting deadlines
  • Uruguay: Reminders for CRS compliance and reporting deadline
  • Financial Action Task Force updates “grey list”

Exempt Organizations

  • IRS TE/GE releases new technical guides for exempt organizations
  • Senate Finance Committee tax title of budget reconciliation bill includes exempt organization provisions

Trade & Customs

  • White House announces executive order implementing trade deal with UK
  • U.S. OFAC announces $3.8 million settlement with Texas-based company for violations of Iran and Venezuela sanctions
  • European Commission proposes phase-out of Russian gas and oil imports
  • Rwanda: Tax and customs proposals for 2025/2026

Africa

  • Mauritius: E-invoicing to become mandatory for new group of taxpayers
  • Nigeria: New cost efficiency incentive framework for upstream oil and gas sector
  • Rwanda: Tax and customs proposals for 2025/2026
  • Tanzania: Tax proposals in 2025/2026 budget
  • Uganda: Tax proposals in 2025/2026 budget

Americas

  • Chile: Consultation on appointment of representative of business groups; other direct and indirect tax developments

Asia Pacific

  • Australia: Consultation on draft instruments related to GST and foreign ownership register
  • Australia: Legislation expanding first home buyer, “off-the-plan” duty concessions passes state Parliament (Western Australia)
  • Australia: Tax measures to promote cost of living relief and housing affordability in 2025-2026 budget (Western Australia)
  • Australia: Further guidance on public country-by-country reporting
  • Bangladesh: Income tax and VAT proposals in Finance Ordinance 2025
  • Hong Kong: Stamp duty group relief only available to associated companies with issued share capital
  • India: Business losses attributable to PE may be offset against interest income not attributable to PE under UAE treaty (tribunal decision)
  • India: Limitation of relief provision under Singapore treaty not applicable to treaty provision relating to taxation of capital gains (tribunal decision)
  • Korea: Royalties for use in Korea of U.S.-registered patents treated as Korean-source under U.S. treaty (Tax Tribunal decision); VAT zero-rating for certain services; other tax developments
  • Vietnam: Change in taxation of capital gains of nonresident shareholders in non-public joint stock companies and LLCs

Europe

  • Croatia: E-invoicing to become mandatory for domestic transactions
  • France: Digital services tax referred to French Constitutional Court
  • Italy: Extended deadline for penalty-protection documentation on hybrid mismatches
  • Netherlands: Report on international tax rulings, including APAs, requested during 2024
  • Netherlands: Government report on concerns relating to new framework for determining characterization for tax purposes of foreign legal forms
  • Poland: Deductibility of price adjustments and training expenses under corporate income tax law
  • Spain: Consultation on draft Pillar Two forms

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