KPMG Week in Tax: October 27 – 31, 2025

Recent tax developments from around the globe for the week of October 27 – 31, 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 recent trade agreements with Cambodia, Malaysia, and Thailand include commitments from these countries not to impose digital services taxes or similar discriminatory measures on U.S. companies. While none of these countries currently have DSTs in place, Malaysia and Thailand do have or are considering other tax mechanisms affecting e-commerce, which may still impact U.S. digital businesses. Read TaxNewsFlash
South Africa: The South African Revenue Service (SARS) has postponed key global anti-base erosion (GloBE) reporting deadlines to mid-2026 and confirmed qualified status for the domestic minimum top-up tax (DMTT), reducing double taxation risks for multinational groups. Read TaxNewsFlash
Malta: The 2026 budget proposes targeted tax relief for families and first-time buyers, enhanced incentives for business investment and R&D, and increased eco-contributions to support tourism infrastructure. Read TaxNewsFlash

United States

Trade agreements with Cambodia, Malaysia, and Thailand include commitments to refrain from imposing DSTs on U.S. companies
IRS provides tax relief for taxpayers affected by storms and flooding in parts of Alaska
IRS provides tax relief for taxpayers affected by storms and flooding in Sisseton-Wahpeton Oyate Tribal Nation in South Dakota and North Dakota
California: Newly enacted law updates IRC conformity
KPMG article: Challenges faced by distressed QOZ businesses

Read TaxNewsFlash-United States

Transfer Pricing

Argentina: Updates to reporting requirements for cross-border transactions
Australia: Consultation on draft legislation amending Pillar Two rules
Australia: Taxpayer granted stay of domestic tax proceedings pending outcome of MAP (Full Federal Court decision)
Australia: Updated guidance on APAs
France: No implementation of Pillar One Amount B, but acceptance of Amount B outcomes in covered jurisdictions
Israel: Value of IP need not include “tax gross-up,” but must include “holdbacks” (District Court decision)
OECD: “Tax Certainty Day” highlights MAP and APA statistics
Slovakia: Legislation amending Pillar Two rules approved by Parliament
Slovakia: Updated guidelines on transfer pricing documentation
South Africa: Updates to GloBE reporting
UK: Updated list of Pillar Two territories, qualifying top-up taxes
UN releases draft template of model tax treaty
KPMG report: “Amsterdam Dialogue on Global Minimum Tax Compliance” stakeholder meeting, October 2025

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Australia: Guidance on reporting certain pre-existing U.S. taxpayer accounts with missing tax IDs
British Virgin Islands: Implementation of CRS 2.0 and CARF

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

EC publishes 2026 version of Combined Nomenclature
Upgraded trade agreement between the EU and Ukraine enters into force
United States announces trade agreements and frameworks with Cambodia, Malaysia, Thailand, and Vietnam

Read TradeNewsFlash-Trade & Customs

Africa

Angola: Automatic submission of periodic VAT return
Angola: Legislation introducing mandatory e-invoicing effective October 1, 2025
Angola: Nonresident nationals tax exempt effective January 1, 2027
Nigeria: Rideshare platform operators may be designated as VAT collection agents (High Court decision)
South Africa: GAAR applied to recharacterize tax-exempt dividends as taxable service fee income (court decision)
South Africa: Updates to GloBE reporting
Tunisia: Proposed 2026 Finance Bill expands mandatory e-invoicing

Read TaxNewsFlash-Africa

Americas

Argentina: Updates to reporting requirements for cross-border transactions
Colombia: Concession contracts and public-private partnership (PPP) schemes not subject to stamp tax
KPMG article: Mexico’s Supreme Court clarifies tax refund procedures, deadlines

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Consultation on draft legislation amending Pillar Two rules
Australia: Taxpayer granted stay of domestic tax proceedings pending outcome of MAP (Full Federal Court decision)
Australia: Updated guidance on APAs
India: Capital gains on indirect share transfer not taxable under Singapore treaty (tribunal decision); other direct and indirect tax developments
Israel: Value of IP need not include “tax gross-up,” but must include “holdbacks” (District Court decision)
Malaysia: Amended and new service tax policies

Read TaxNewsFlash-Asia Pacific

Europe

Cyprus: Tax reform proposal submitted to Parliament
Estonia: “Construction services” in Finland held intra-community supply of goods subject to VAT (Circuit Court decision)
France: No implementation of Pillar One Amount B, but acceptance of Amount B outcomes in covered jurisdictions
France: VAT exemption lists for Guadeloupe, Martinique, and Réunion
Germany: Draft legislation to expand MLI to 62 additional treaties; other tax developments
Italy: Role of fixed establishment in negotiating contracts; standard VAT rate for hearing aid repair services
Latvia: Proposed changes to application of reduced VAT rates for publications and food products
Lithuania: Amendments to corporate income taxation effective January 1, 2026
Malta: New 15% tax rate for senior employees in family offices and treasury operations
Malta: Tax measures in 2026 budget
Poland: New rules concerning carbon border adjustment mechanism (CBAM)
Poland: Reduced excise duty for hybrid vehicles; hidden profits of CEO; VAT treatment of granting loan; government R&D funds not subject to VAT
Slovakia: Legislation amending Pillar Two rules approved by Parliament
Slovakia: Updated guidelines on transfer pricing documentation
Slovenia: Mandatory e-invoicing for B2B transactions
Spain: Timeline for adaptation of invoicing systems
UK: Guidance on R&D tax relief for small and medium-sized enterprises
UK: Updated list of Pillar Two territories, qualifying top-up taxes

Read TaxNewsFlash-Europe

Other publications

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

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