KPMG Week in Tax: August 18 – 22, 2025

Recent tax developments from around the globe for the week of August 18 – 22, 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 U.S. Treasury and IRS have issued proposed regulations concerning partnership reporting requirements for sales involving section 751(a) property. Partnerships may rely on these changes for applicable transactions starting January 1, 2025, with final rules pending, and comments due by September 18, 2025. Read TaxNewsFlash
United States-European Union: An agreement on a comprehensive trade framework will eliminate EU tariffs on U.S. industrial goods, grant preferential access for U.S. agriculture, and set new tariff rates on EU imports effective September 1, 2025, while also addressing key sectors such as pharmaceuticals, semiconductors, energy, and defense. The agreement includes commitments to reduce non-tariff barriers and enhance cooperation on standards, cybersecurity, and labor rights. Read TradeNewsFlash
Canada: The Department of Finance released draft legislation addressing excessive interest and financing expenses limitation (EIFEL) exemptions, scientific research and experimental development (SR&ED) tax incentives, Canadian-controlled private corporations (CCPCs), capital gains deferral and exemptions, and enhanced reporting for trusts and non-profits. Finance also released draft legislation for the Global Minimum Tax Act, the Excise Tax Act and several other Income Tax Act technical tax amendments. Comments will be accepted until September 12, 2025. Read TaxNewsFlash

United States

Proposed regulations: Information reporting for sales or exchanges to which section 751(a) applies
Notice 2025-44: Intent to issue proposed regulations removing disregarded payment loss (DPL) rules
Notice 2025-45: Intent to issue proposed regulations under sections 897 relating to certain F reorganizations involving transfer of USRPIs
Tenth Circuit: Section 904(f)(3)(A) does not prevent recognition of gain in excess of overall foreign loss account
IRS issues FAQs for modification of several energy credits and deductions expiring under OBBBA
IRS accepting applicants for 2026 CAP program beginning September 3
Inflation adjustment factor and applicable amounts for clean electricity production credit under section 45Y
KPMG report: OBBBA changes to section 45S employer credit for paid family and medical leave

Read TaxNewsFlash-United States

Transfer Pricing

Bahrain: Updated guidance on domestic minimum top-up tax (DMTT)
Canada: Finance releases draft tax legislation package, including global minimum tax and excise tax changes
Germany: Draft amendments to Pillar Two rules
South Africa: Reduced interest rate for taxation of interest-free or low-interest loans

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Costa Rica: Resolution on CRS due diligence and compliance amendments
OECD: Updated FAQs on CARF and CRS, and revised CARF XML schema user guide
Singapore: Implementation of CRS XML schema v3.0
UK: Revised penalty framework; updated International Exchange of Information manual

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

United States and European Union announce trade framework agreement
U.S. BIS requests comments on Section 232 investigation of imports of wind turbines
United States publishes 2025 updates to Uyghur Forced Labor Prevention Act enforcement strategy

Read TradeNewsFlash-Trade & Customs

Africa

South Africa: Increase in fuel levies
South Africa: Proposed amendment to repeal exemption for certain dividends recognized under IFRS
South Africa: Proposed amendment to rules allowing deferral of foreign currency gain or loss on certain related-party debts
South Africa: Proposed changes to anti-avoidance rules for hybrid equity instruments
South Africa: Reduced interest rate for taxation of interest-free or low-interest loans
South Africa: Updated guide on royalties withholding tax return

Read TaxNewsFlash-Africa

Americas

Brazil: Updated e-invoicing layout to align with tax reform 2026 (São Paulo City)
Canada: Finance releases draft tax legislation package, including global minimum tax and excise tax changes
Chile: Procedure for registration in simplified VAT regime; other direct and indirect tax developments
Colombia: Applications open for research, development, and innovation projects eligible for tax benefits

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Final guidance on application of anti-avoidance rules to restructuring transaction in response to thin capitalization rules
Australia: Taxpayer not liable for withholding tax on embedded royalties or subject to DPT (High Court decision)
Bahrain: Updated guidance on domestic minimum top-up tax (DMTT)
India: Interest on “external commercial borrowing” exempt under Mauritius treaty (High Court decision)
India: Split verdict on issue relating to time limit for completion of assessment proceedings (Supreme Court decision)
Kazakhstan: Public consultation on proposed framework for “conditional VAT registration”

Read TaxNewsFlash-Asia Pacific

Europe

Germany: Draft amendments to Pillar Two rules; other tax developments
Norway: Portion of international cruises taking place in Norway subject to VAT (Oslo District Court decision)
Poland: Company’s tax liability cannot be challenged in suit against member of company’s board; holiday pay includible in R&D eligible costs (Supreme Administrative Court decisions)
Poland: Intent to introduce new windfall profits tax on banking sector announced; proposed legislation introducing packaging fee
Poland: Proposed extension of exemption from obligation to apply pay and refund mechanism in withholding tax for payments made through intermediary remitters

Read TaxNewsFlash-Europe

Other publications

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

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