KPMG Week in Tax: September 1 – 5, 2025

Recent tax developments from around the globe for the week of September 1 – 5, 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).

EU: The CJEU has ruled that intra-group transfer pricing payments calculated using the transactional net margin method are subject to value added tax (VAT), as they constitute consideration for services provided under inter-company agreements. Read TaxNewsFlash
United States: The Trump Administration has petitioned the U.S. Supreme Court to review whether the president has authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs in response to national emergencies, following a Federal Circuit decision that such tariffs were not legally authorized. Read TradeNewsFlash
Uruguay: The proposed National Budget Bill introduces a domestic complementary minimum tax (IMCD) aligned with the OECD’s global minimum tax standards, ensuring multinational groups pay at least a 15% effective tax rate locally. While expected to generate significant additional revenue, the IMCD may reduce the benefits of existing investment promotion regimes (including free zones and the software sector). Read TaxNewsFlash

United States

Treasury Department Spring 2025 agenda of regulatory actions
Eighth Circuit: Tax Court’s application of unspecified transfer pricing method rejected
Proposed regulations withdrawn: Disclosure of returns and return information to contractors who assist in revocation or denial of passports

Read TaxNewsFlash-United States

JCT overview of federal tax system (2025)

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

Australia: Consultation on draft legislation providing exemptions from obligation to file Pillar Two tax returns
EU: Intra-group payments under the transactional net margin method subject to VAT (CJEU judgment)
Slovakia: Bill implementing DAC8 approved by Parliament; consultation on implementation of DAC9
Switzerland: Updated list of jurisdictions for exchange of country-by-country reports
UK: Updates to new guidance manual on Pillar Two
United States: Tax Court’s application of unspecified transfer pricing method rejected (Eighth Circuit)
Uruguay: Budget proposals include Pillar Two minimum tax
Vietnam: Guidance on implementation of Pillar Two rules

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Anguilla: Proposed adoption of amended CRS
Switzerland: Consultation on introducing AEOI agreements with eight additional jurisdictions

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

U.S. CBP issues correcting amendments to USMCA regulations
U.S. implementation of framework agreement with Japan
Trump Administration seeks Supreme Court review of court decision blocking tariffs under IEEPA
U.S. OFAC announces Texas-based freight forwarder to pay $1.6 million for violations of multiple sanctions programs
Federal Circuit: Presidential tariffs exceeded legal authority under International Emergency Economic Powers Act (IEEPA)
European Commission proposes tariff reductions to implement EU-US deal
Colombia: Changes to tax reimbursement for exports of goods and services

Read TradeNewsFlash-Trade & Customs

Africa

South Africa: Proposed changes to anti-avoidance rules for hybrid equity instruments withdrawn
Mali: New taxes on telecommunication services and mobile money transactions

Read TaxNewsFlash-Africa

Americas

Argentina: Amendments to income tax advance payment regime and installment regime
Argentina: Property transfer code requirement eliminated
Argentina: Reduced excise taxes and tariffs on cell phones and other electronic products
Canada: Relief from withholding tax on reimbursements to nonresident subcontractors extended to June 30, 2026
Colombia: Changes to tax reimbursement for exports of goods and services
Uruguay: Budget proposals include Pillar Two minimum tax

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Consultation on draft legislation providing exemptions from obligation to file Pillar Two tax returns
India: Capital gains from transfer of derivatives not taxable under India-Mauritius treaty; seconded employees did not create PE in India (court decisions)
India: General anti-abuse rule (GAAR) did not apply to taxpayer’s capital loss (High Court decision)
India: Recommendations of GST Council meeting
Kazakhstan: Reduction in scope of VAT-exempt transactions
Vietnam: Guidance on implementation of Pillar Two rules

Read TaxNewsFlash-Asia Pacific

Europe

Czech Republic: Proposed changes to R&D allowances
EU: Intra-group payments under the transactional net margin method subject to VAT (CJEU judgment)
Greece: Corporate income taxation of previously untaxed undistributed profits aligns with parent subsidiary directive (Supreme Administrative Court decision)
Greece: VAT on commercial pleasure vessels based on expiration of licence
Ireland: Updated guidance on adoption of directive on administrative cooperation in taxation (DAC)
Luxembourg: Proposed tax benefits for carried interest, stock options, angel investment
Malta: Tax rebates for individuals abolished from 2026
Poland: Council of Ministers preliminarily approves 2026 budget bill, including increase in corporate tax for banking sector
Poland: Exemption from withholding tax not conditional on verification of recipient’s beneficial owner status; rules governing refusal to issue clearance opinion (Supreme Administrative Court decisions)
Poland: Guidance on liability of management board members for company’s tax assessments
Serbia: Updates to system of electronic invoicing
Slovakia: Bill amending excise duties on energy approved by Parliament
Slovakia: Bill implementing DAC8 approved by Parliament; consultation on implementation of DAC9
Sweden: Draft legislation exempting foreign states and municipalities from withholding tax
Switzerland: Updated list of jurisdictions for exchange of country-by-country reports
UK: Guidance on taxpayer declaration that tax return information is correct and complete
UK: Guidance on taxation of lease in-lease out (LILO) arrangements
UK: Updates to new guidance manual on Pillar Two
Ukraine: Import of fiber optic drones exempt from VAT

Read TaxNewsFlash-Europe

Other publications

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

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