KPMG Week in Tax: July 14 – 18, 2025

Recent tax developments from around the globe for the weeks of July 14 – 18, 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).

Australia: Draft guidance details transitional approaches and expectations for Pillar Two filing obligations, including the consolidation of various tax returns into the Combined Global and Domestic Minimum Tax Return (CGDMTR) and the implementation of the OECD’s transitional penalty relief framework. The guidance allows multinational enterprise groups to nominate a designated local entity for filing obligations, with the first filings due in 2026, and outlines penalty remittance and compliance measures during the transition period. The draft guidance is open for consultation until August 29, 2025. Read TaxNewsFlash
Chile: Resolution 79/2025 mandates government entities, financial institutions, and digital platforms to verify that businesses operating in Chile have informed the tax authority (SII) of their commercial activities, requiring cross-checking of tax IDs against the SII database. Digital marketplaces and payment facilitators must submit client databases for verification by October 30, 2025, with non-compliance resulting in sanctions under the Chilean Tax Code, and further regulations anticipated for implementation. Read TaxNewsFlash
EU: The European Commission's proposal for a Council Decision suggests expanding the EU's own resources system by incorporating contributions based on the carbon border adjustment mechanism (CBAM) and emissions trading system (ETS), alongside three new resources: a corporate resource based on turnover, an e-waste contribution, and a tobacco excise duty. These changes, requiring unanimous member state approval, aim to enhance EU budget funding and are set to be implemented by January 1, 2028, with the corporate levy starting January 1 of the first calendar year following the year in which the Council Decision becomes effective. Read TaxNewsFlash

United States

IRS descriptions of new tax deductions in “One Big Beautiful Bill”
IRS announces tax relief for taxpayers affected by storms, flooding, and landslides in New Mexico
Notice 2025-37: Inflation adjustment factors and applicable amounts for credits under sections 45U, 45V, and 45Z
Notice 2025-40: Mortality tables for defined benefit pension plans (2026)
Rev. Rul. 2025-15: Guidance on uncashed retirement distribution checks and their replacements
KPMG article: IRS announces improvements to its pre-filing agreement program
KPMG article: Proposal to end citizenship-based taxation for U.S. citizens living overseas
KPMG article: Retail delivery fees generate some bumps in the road
KPMG article: State and local tax approaches to the definition of a “platform”
KPMG article: Treaty-based foreign tax credit and net investment income tax
KPMG article: U.S. tax provisions in the SHIPS Act of 2025

Read TaxNewsFlash-United States

Transfer Pricing

Australia: Draft guidance on Pillar Two filing obligations
Belgium: Obligation to pay top-up tax under UTPR on low-taxed profits of group members outside Belgium (CJEU referral)
Dominica: Government introduces country-by-country reporting legislation
France: Obligations between taxpayers and FTA under advance pricing agreements (APAs)
Germany: Application of transaction matrix requirement for transfer pricing
OECD: Reports on developments in international tax cooperation and transparency
KPMG report: Year-end tariff refunds

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Costa Rica: Updated FATCA and CRS reporting deadline
Japan: Upcoming changes to domestic framework aligned with 2022 CRS amendments

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

USTR launches Section 301 investigation into Brazil’s trade practices
U.S. BIS requests comments on Section 232 investigations into imports of unmanned aircraft systems and polysilicon
U.S. OFAC announces settlement agreement with brokerage firm for violations of sanctions programs
KPMG report: Year-end tariff refunds
Kenya: Independent review for customs disputes

Read TradeNewsFlash-Trade & Customs

Africa

Nigeria: New law rebrands the tax authority
Nigeria: Tax reform and the power sector
Kenya: Independent review for customs disputes

Read TaxNewsFlash-Africa

Americas

Chile: New obligations for digital marketplaces, payment facilitators, and government agencies
Costa Rica: Guidelines for disabling current platforms in preparation for implementation of new digital tax system
Dominican Republic: Mandatory e-invoicing for small businesses
Mexico: New guidelines on tax refund requests
Mexico: Constitutionality of emissions tax confirmed by court decision (State of Mexico)
Saint Kitts and Nevis: Tourism development levy to increase to 3%
Venezuela: Requirements for special economic zones incentives

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Draft guidance on Pillar Two filing obligations
Australia: GST treatment on refunds under container deposit scheme
Bahrain: Updated VAT guides
Kazakhstan: Amendments to individual income tax
Malaysia: Tax developments summary (July 2025)
Singapore: Guidance on corporate income tax filing season 2025
Singapore: Updated guide on GST concession for REITs, qualifying registered business trusts
UAE: Clarification of VAT recovery on SWIFT Messages limited to financial institutions

Read TaxNewsFlash-Asia Pacific

Europe

Belgium: Obligation to pay top-up tax under UTPR on low-taxed profits of group members outside Belgium (CJEU referral)
Cyprus: Transition to TFA system for tax withholding submissions and payments
Denmark: Parliament passes tax bills concerning shareholder loans and green assets
EU: EC proposal for system of own resources
France: Obligations between taxpayers and FTA under advance pricing agreements (APAs)
France: Rate limits for interest deductibility of interest paid to shareholders
France: Updated administrative guidelines for VAT treatment of composite supplies
Germany: Import VAT on re-importation of goods; other VAT developments
Latvia: Draft amendments partially implementing DAC8
Latvia: Proposal to postpone mandatory B2B e-invoicing until 2027
Luxembourg: Proposed legislation includes tax credit for start-up companies
Netherlands: Rebuttal provision in Box 3 (“wealth tax”) approved by upper house of Parliament
Poland: Application of beneficial owner clause in withholding tax
Poland: Clearance opinion issued on sequence of activities involving family foundation
Poland: Requirement to submit declaration to use registered residence relief is unconstitutional (tribunal decision)
Poland: Retroactive changes to tax depreciation rates (Supreme Administrative Court)
KPMG report: Shipping and offshore tax update (July 2025)

Read TaxNewsFlash-Europe

Other publications

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

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