KPMG Week in Tax: June 23 – 27, 2025

Recent tax developments from around the globe for the week of June 23 – 27, 2025

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June 30, 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: Updated legislative text for the budget reconciliation bill includes significant changes such as increasing the SALT cap and altering green energy credits. Following an agreement between Treasury and the other G7 countries, the proposed new section 899 has been removed from the bill, which would have imposed a retaliatory tax on certain non-U.S. corporations and individuals. Read TaxNewsFlash
  • UK: HM Revenue & Customs (HMRC) has updated its international manual to include guidance and a sample agreement for advance pricing agreements (APAs) and cost contribution arrangements (CCAs), allowing groups with existing development CCAs to request an APA and confirming openness to APA terms longer than five years based on project duration. Read TaxNewsFlash
  • Vietnam: The National Assembly passed a resolution effective September 1, 2025, introducing tax incentives for International Financial Centres (IFCs), including a 10% corporate income tax rate for 30 years for certain sectors and individual income tax exemptions for experts until 2030. Read TaxNewsFlash

 

United States

  • Treasury announces agreement with G7 countries to exclude U.S. companies from Pillar Two taxes in exchange for removing proposed new section 899 from OBBB
  • Senate confirms Kies to be Treasury Assistant Secretary (Tax Policy)
  • IRS announces tax relief for taxpayers affected by storms in Missouri
  • National Taxpayer Advocate mid-year report to Congress
  • Notice 2025-31: Guidance for energy community bonus credit under sections 45, 45Y, 48, and 48E
  • Washington State: Temporary expansion of voluntary disclosure agreement (VDA) program for investment income subject to B&O tax
  • KPMG article: Proposed new SALT regime and passthroughs

Transfer Pricing

  • EU: Report following June 2025 ECOFIN meeting
  • Korea: Annually updated benchmarking allowed (Tax Tribunal decision)
  • KPMG article: “Materiality” limits on deductions for services in Mexico
  • Netherlands: Mutual agreement procedures team annual report for 2024
  • Romania: Draft form for declaration and payment of domestic top-up tax under Pillar Two rules
  • UK: Updated manual on advance pricing agreements (APAs) and cost contribution arrangements (CCAs)
  • United States: Treasury announces agreement with G7 countries to exclude U.S. companies from Pillar Two taxes in exchange for removing proposed new section 899 from OBBB
  • Vietnam: Approval of bilateral and multilateral APAs delegated to Minister of Finance

FATCA / IGA / CRS

  • Belgium: Opening of CRS portal and extended CRS reporting deadline announced
  • Germany: Updated FATCA and CRS guidance
  • Gibraltar: CRS compliance program and voluntary disclosure opportunity
  • South Africa: Draft notice for public comment on revised CRS penalty framework

Africa

  • Nigeria: Proposed legislation to reform tax system
  • South Africa: Updated guidance on tax return for companies, beneficial ownership reporting

Americas

  • Colombia: Guidance on works as form of payment of tax obligations (Bogotá Capital District)
  • KPMG article: “Materiality” limits on deductions for services in Mexico
  • Mexico: List of 260 registered foreign providers of digital services (as of April 30, 2025)
  • Montserrat: Tax measures in 2025/2026 budget
  • Uruguay: Extended deadline for real estate tax incentives

Asia Pacific

  • Australia: Conveyance duty concessions in 2025-2026 budget (Australian Capital Territory)
  • Australia: Tax measures in 2025 budget (Queensland)
  • Australia: Tax measures in 2025-2026 budget (New South Wales)
  • Bahrain: Updated transfer of going concern VAT guide
  • India: Conversion of private company into LLP was taxable transfer (tribunal decision)
  • Japan: Guidance on “payments economically equivalent to interest” for purposes of earnings stripping rules
  • Korea: Annually updated benchmarking allowed (Tax Tribunal decision)
  • Oman: New law for special economic zones and free zones
  • Saudi Arabia: Guidance on Zakat rules
  • Singapore: Guidance on country-of-origin declaration rules
  • Vietnam: Approval of bilateral and multilateral APAs delegated to Minister of Finance
  • Vietnam: Tax incentives for “International Financial Centres”

Europe

  • Cyprus: VAT law amendments on place of supply for virtual events
  • EU: Report following June 2025 ECOFIN meeting
  • Germany: Legislation aimed at stimulating investment passed by lower house of Parliament
  • Germany: Planned digital levy for large digital platforms; other tax developments
  • Ireland: Return filing and payment deadline extended for taxpayers using Revenue Online Service (ROS)
  • Latvia: Implementation of e-invoicing system for B2B transactions postponed
  • Moldova: Consultations regarding indirect tax calculations and new tax rules for independent entrepreneurs
  • Netherlands: Mutual agreement procedures team annual report for 2024
  • Poland: Bill on national electronic invoicing system (KSeF) passed by Council of Ministers
  • Romania: Draft form for declaration and payment of domestic top-up tax under Pillar Two rules
  • Spain: EC decision that law allowing companies to deduct goodwill resulting from indirect stock acquisitions annulled (CJEU judgment)
  • UK: Updated manual on advance pricing agreements (APAs) and cost contribution arrangements (CCAs)

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