KPMG Week in Tax: September 15 – 19, 2025

Recent tax developments from around the globe for the week of September 15 – 19, 2025

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September 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: Proposed regulations define “qualified tips” and list tipped occupations for the new income tax deduction under the “One Big Beautiful Bill Act,” effective for tax years 2025-2028; the deduction is capped at $25,000 and phases out for higher incomes, with detailed rules to prevent abuse and clarify eligible payments and occupations. Read TaxNewsFlash
  • Netherlands: The government submitted the 2026 Tax Plan to Parliament, outlining proposed changes across corporate and individual income tax, global minimum tax (including OECD administrative guidance and DAC9 implementation), payroll and social security, VAT, procedural law, inheritance and gift tax, environmental taxation, and other miscellaneous provisions. Read TaxNewsFlash
  • Greece: Electronic invoicing for domestic B2B transactions will be mandatory starting in 2026, with large enterprises (greater than €1 million revenue) mandated to comply from February 2, 2026, and all other businesses from October 1, 2026. Early adopters benefit from enhanced tax deductions, and compliance can be achieved via certified providers or free tools. Read TaxNewsFlash

United States

  • Advance notice of proposed rulemaking: GENIUS Act implementation
  • Application of income tax treaties to branch profits tax of certain hybrid entities
  • Final regulations: Guidance on catch-up contributions to retirement plans
  • IRS provides tax relief for taxpayers affected by storms and flooding in parts of Wisconsin
  • Notice of 39 substances added to Superfund list
  • Proposed regulations: Occupations that customarily and regularly receive tips and definition of “qualified tips”

Read TaxNewsFlash-United States

  • House Ways and Means approves two bills aimed at improving tax administration; JCT descriptions

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Czech Republic: Amendments to Pillar Two rules signed by president 
  • Germany: Legislation incorporating authorized OECD approach to PEs not an independent rule for determining PE profit (Federal Fiscal Court decision) 
  • Kazakhstan: Changes to definitions, legal principles under new Tax Code 
  • Malta: Regulations on 15% “elective tax” published 
  • Mauritius: Assessment Review Committee upholds arm's length principle for domestic interest-free loans 
  • Moldova: Annual submission of transfer pricing file no longer required 
  • Netherlands: Government submits 2026 Tax Plan to Parliament, including Pillar Two changes and implementation of DAC9 
  • Netherlands: Proposal to mitigate interest on underpaid tax when MAP conducted 
  • OECD: Pillar Two transitional qualified status achieved by Jersey and Isle of Man 
  • OECD: Updated list of signatories to the GloBE Information Return (GIR) MCAA 
  • Poland: Consultations on Pillar Two forms and anti-avoidance regulations; other tax developments 
  • Portugal: Pillar Two notification form and instructions 
  • Ukraine: Constituent entities of MNE groups parented in U.S., Canada, or Israel must file 2024 CbC reports locally

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Finland: Update on extension of temporary relief for missing U.S. TINs
  • South Africa: FATCA and CRS third-party data bi-annual submission period

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • European Commission proposes suspension of trade provisions with Israel 
  • U.S. BIS establishes Section 232 automobile parts tariff inclusions process 
  • U.S. BIS opens inclusions window for Section 232 steel and aluminum tariff inclusions process 
  • U.S. BIS renews temporary denial of export privileges of three Russian airlines 
  • U.S. CBP modernization of tonnage tax process 
  • USTR seeks comments on extending China-related Section 301 exclusions

Read TradeNewsFlash-Trade & Customs

Africa

  • Ethiopia: Tax amendments passed by House of Peoples’ Representatives 
  • Kenya: Commissions earned by payment service provider exempt from VAT (High Court decision) 
  • Mauritius: Assessment Review Committee upholds arm's length principle for domestic interest-free loans 
  • Tunisia: Clarification to real estate valuation procedure for preliminary tax audits 
  • Tunisia: Guidance on new mandatory e-invoicing measures for B2B and large companies 
  • Uganda: Three-year tax exemption for certain start-up businesses

Read TaxNewsFlash-Africa

Americas

  • Brazil: Legislation suspending increases to financial transaction tax (IOF) rates overturned (Federal Supreme Court decision) 
  • Brazil: Proposed amendments to indirect tax reform 
  • Canada: Removal of retaliatory tariffs on certain U.S. goods 
  • Canada: Upcoming deadlines for distributed investment plans under GST/HST rules
  • Mexico: List of 268 registered foreign providers of digital services (as of August 31, 2025)

Read TaxNewsFlash-Americas

Asia Pacific

  • Bahrain: Updated imports and exports VAT guide 
  • Bangladesh: Summary of tax laws as amended by Finance Ordinance 2025 
  • Cambodia: Implementation of 0% customs duty on eligible U.S.-origin goods 
  • China: New reporting rules for digital platform operators 
  • India: Exemption from withholding tax on specific payments to Financial Centre units 
  • India: Principal purpose test under MLI cannot be applied without specific notification in India-Ireland treaty (tribunal decision) 
  • New Zealand: August tax bill includes changes to tax residence rules for “nonresident visitors” 
  • Philippines: VAT exemption for medicines 
  • Singapore: Tax treatment of consideration received for transfer of certain intellectual property

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Beneficial ownership not required for withholding tax exemption under Belgian law implementing EU interest-royalty directive (court decision) 
  • Belgium: Recovery of wage tax and withholding tax on dividends, interest, or royalties 
  • Czech Republic: Amendments to Pillar Two rules signed by president 
  • EU: CJEU Advocate General opinion on VAT treatment of points earned under loyalty program (Sweden) 
  • EU: CJEU referral on interpretation of tax dispute resolution mechanisms directive (Latvia) 
  • EU: CJEU referral on tax free treatment of partial division under merger directive (Poland) 
  • EU: CJEU referral on VAT group ownership requirements (Denmark) 
  • France: Digital services tax upheld (Constitutional Court decision) 
  • Germany: Draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8) 
  • Germany: Legislation incorporating authorized OECD approach to PEs not an independent rule for determining PE profit (Federal Fiscal Court decision) 
  • Greece: Compliance deadlines for e-invoicing 
  • Italy: Implementation of corporate income tax relief under Budget Law 2025 
  • Latvia: Amendments to tax law aimed at reducing administrative burdens 
  • Malta: Regulations on 15% “elective tax” published 
  • Moldova: Annual submission of transfer pricing file no longer required 
  • Moldova: VAT rules for electricity and natural gas supplies 
  • Netherlands: Government submits 2026 Tax Plan to Parliament, including Pillar Two changes and implementation of DAC9 
  • Netherlands: Proposal to mitigate interest on underpaid tax when MAP conducted 
  • OECD: Pillar Two transitional qualified status achieved by Jersey and Isle of Man 
  • Poland: Consultations on Pillar Two forms and anti-avoidance regulations; other tax developments 
  • Poland: Taxable VAT base for voucher; use of motor vehicles for business versus personal use for VAT purposes (Supreme Administrative Court decisions) 
  • Portugal: Pillar Two notification form and instructions 
  • Romania: Proposal to repeal VAT exemption for NGOs 
  • Slovakia: Guidance on financial transaction tax 
  • Slovakia: Recent developments affecting tax depreciation and deductions for various business sectors 
  • Sweden: Canadian fund qualifies for withholding tax exemption for non-UCITS funds (Administrative Court of Appeal decision) 
  • UK: Interim report on Business Rates system 
  • UK: New stock market for private companies with stamp duty exemptions 
  • Ukraine: Constituent entities of MNE groups parented in U.S., Canada, or Israel must file 2024 CbC reports locally 
  • Ukraine: Proposed extension of VAT exemption for electric vehicles; documentation requirements for VAT exemption for defense-related entities

Read TaxNewsFlash-Europe

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