KPMG Week in Tax: October 20 – 24, 2025

Recent tax developments from around the globe for the week of October 20 – 24, 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 to simplify the rules for determining whether a qualified investment entity (QIE) is domestically controlled would remove the “look-through” requirement for non-public domestic C corporations. This change responds to industry concerns about legal uncertainty and operational burdens and is intended to encourage investment in U.S. real estate by providing clearer, more practical guidance. Read TaxNewsFlash
France: The draft 2026 Finance Bill proposes a one-year extension (at reduced rates) of the exceptional surtax on large companies’ corporate income tax and the 20% minimum tax on high-income taxpayers, accelerates the phase-out of the CVAE to 2028, and introduces a new 2% tax on non-operational assets held by asset holding companies. The bill also updates Pillar Two rules to incorporate the latest OECD guidance and transposes the EU’s DAC9 directive. Read TaxNewsFlash
Australia: Updated guidance on the Pillar Two transitional country-by-country (CbC) reporting safe harbor outlines eligibility conditions, effects, applicable transition periods, and details how to apply the three safe harbor tests: de minimis, simplified effective tax rate, and routine profits. This aims to help taxpayers determine if they qualify for simplified compliance under the new global and domestic minimum tax rules. Read TaxNewsFlash

United States

Proposed regulations: Removal of domestic corporation look-through rule in applying exception for domestically controlled qualified investment entities under section 897(h)
Notice 2025-57: Transitional guidance for businesses required to report interest received on qualified passenger vehicle loans
Notice 2025-63: Intent to issue proposed regulations providing source of certain borrow fees determined based on residence of recipient
IRS issues FAQs on limitation enacted under OBBBA on credits and refunds for employee retention credits
IRS issues revised FAQs on Form 1099-K, reflecting changes to reporting thresholds enacted by OBBBA
U.S. Tax Court: Equitable tolling does not apply to prescribed periods for filing TEFRA petition

Read TaxNewsFlash-United States

Transfer Pricing

Australia: Guidance on transitional CbC reporting safe harbor under Pillar Two rules
Belgium: Guidance on implementation of Pillar Two rules
Belgium: Interest rate on intra-group loan held non-arm’s length under comparable uncontrolled price method (court decision)
EU: Updates on tax initiatives in EC 2026 Work Programme
France: Tax measures in 2026 Finance Bill include amendments to Pillar Two rules
Hungary: Tax declaration Form 24GLBADO for qualifying domestic minimum top-up tax
OECD: Third batch of updated transfer pricing country profiles

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Barbados: Guidance on collection of TIN under CRS
EU: Amending protocol with Switzerland to strengthen tax cooperation
Liechtenstein: Statement adopted on CARF, amended CRS, and protocol signed with EU amending AEOI agreement
Monaco: Protocol with EU amending AEOI agreement signed
Uruguay: CRS reporting deadline extended to November 30, 2025
Uruguay: Proposed changes to tax transparency measures in budget bill

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

EU adopts 19th package of sanctions against Russia
U.S. Treasury sanctions Russian oil companies
United States imposes 25% tariffs on medium- and heavy-duty vehicle imports
USTR proposed actions against Nicaragua following Section 301 investigation
USTR initiates Section 301 investigation into China’s implementation of the “Phase One Agreement”

Read TradeNewsFlash-Trade & Customs

Americas

Colombia: Amended rules for filing foreign exchange information
Mexico: Changes to tax controversy rules
Mexico: Weather-related tax relief for taxpayers in Hidalgo
OECD: Brazil signs MLI
Uruguay: Changes to valuation of rural properties for purposes of wealth tax
Uruguay: Income tax proposals in draft budget bill 2025-2029
Uruguay: Reduction in specific internal tax (IMESI) on gasoline sales at border crossings
Uruguay: Simplified customs procedure allows exemption for small retail businesses from VAT and specific internal tax

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Foreign/absentee surcharge land taxes constitutionally valid (High Court decision)
Australia: Guidance on transitional CbC reporting safe harbor under Pillar Two rules
Australia: Taxpayers liable for payroll taxes for subcontractors (Supreme Court of New South Wales decision)
Bahrain: Updates to VAT guides in 2025
Georgia: Self-constructed buildings for business purposes are subject to VAT under certain conditions
Kazakhstan: Proposed amendments to e-invoicing rules
Malaysia: Amendments to service tax policies
Philippines: E-invoicing compliance deadline extended to December 31, 2026
Sri Lanka: Amended bonded warehouse facility regulations
UAE: Guidance on valuation method under transitional rules for disposal of qualifying immovable property by real estate developers

Read TaxNewsFlash-Asia Pacific

Europe

Austria: Proposed changes to real estate transfer tax on share transfers
Belgium: Guidance on implementation of Pillar Two rules
Belgium: Interest rate on intra-group loan held non-arm’s length under comparable uncontrolled price method (court decision)
EU: Amending protocol with Switzerland to strengthen tax cooperation
EU: Updates on tax initiatives in EC 2026 Work Programme
France: Tax measures in 2026 Finance Bill include amendments to Pillar Two rules
Georgia: Self-constructed buildings for business purposes are subject to VAT under certain conditions
Germany: VAT measures included in Tax Amendment Act of 2025; other VAT developments
Greece: Guidance on applicability and administrative aspects of cruise tax
Greece: Guidance on certificates for income tax return of residents employed in other EU member states
Hungary: Tax declaration Form 24GLBADO for qualifying domestic minimum top-up tax
Lithuania: New security contribution on non-life insurance premiums as of 2026
Moldova: Guidance on requirements to apply SME tax regime
Moldova: Implementation of taxation of immovable property based on market value postponed
Netherlands: Dividend withholding tax exemption denied to structures aimed at tax avoidance (Supreme Court decision)
Netherlands: Guidance on scope of ATAD interest deduction limitation rules
Netherlands: Updated “Q&A decree” on innovation box
Poland: Amendments to taxation of banks, corporate income tax rules, excise duty on alcoholic beverages, fees on sugar/caffeine content in beverages
Serbia: Public consultation on draft “green tax” laws
Spain: New H1 system for electronic declaration of imports mandatory as of October 14, 2025
Ukraine: Moratorium of tax audits for certain business entities signed by president

Read TaxNewsFlash-Europe

Other publications

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

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