KPMG Week in Tax: September 29 – October 3, 2025

• KPMG report: Additional CAMT interim guidance and favorable early reliance rules
• Notices 2025-46 and 2025-49: Interim guidance on CAMT, intent to withdraw prior proposed regulations
• Notice 2025-50: Guidance regarding substantial improvements to property located in QOZ comprised entirely of “rural area”
• Notice 2025-53: New tax relief for taxpayers affected by terroristic action in Israel
• Final regulations: Interest capitalization requirements for improvements that constitute designated property
• Final regulations: Recordkeeping and reporting requirements for average income test under section 42 low-income housing credit
• Proposed regulations withdrawn: Guidance on corporate separations, incorporations, and reorganizations qualifying for nonrecognition of gain or loss
• Rev. Proc. 2025-30: Updated procedures for section 355 private letter rulings
• Eighth Circuit: Reallocation of blocked royalty income not allowed under section 482
• IRS launches two-year post appeals mediation pilot program
• IRS Priority Guidance Plan for 2025-2026
• IRS extends period for feedback on Form 6765 for research credit
• Government shuts down, IRS to remain fully operational for at least five days
• KPMG report: Transfer pricing and international tax year-end considerations

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• Final regulations: Recordkeeping and reporting requirements for average income test under section 42 low-income housing credit
• IRS Priority Guidance Plan for 2025-2026—exempt organization projects
• Social welfare standards for exemption held unconstitutionally vague (federal district court decision)

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• Belgium: Transfer pricing dispute concerning royalties, factoring fees, and interest deductions (court decision)
• EU: Update on European Trust and Cooperation Approach to transfer pricing, BEFIT proposal, creation of Capital Markets Union
• Germany: Draft amendments to Pillar Two rules adopted by Federal Cabinet; draft bill to implement DAC8; other tax developments
• Korea: Royalties from patents not registered in Korea may be subject to tax in Korea under U.S. treaty (Supreme Court decision); other tax developments
• KPMG report: Transfer pricing and international tax year-end considerations
• Kuwait: Electronic registration service for companies subject to domestic minimum top-up tax (DMTT) launched
• Spain: Arm’s length remuneration in cash pooling arrangements of multinational groups (Supreme Court decision)
• Switzerland: GloBE reporting regulations adopted by Federal Council
• United States: Reallocation of blocked royalty income not allowed under section 482 (Eighth Circuit)

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• United States: IRS updates “public key” for FATCA filing

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• U.S. BIS expands export controls to foreign affiliates of listed entities under new ownership rule
• U.S. BIS issues penalties and settlements for export violations
• U.S. BIS renews temporary denial of export privileges for Russian airline
• United States imposes Section 232 tariffs on imports of timber, lumber, and wood products

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• Angola: Mandatory e-invoicing implementation postponed
• Kenya: Public consultation on application of significant economic presence (SEP) tax
• KPMG report: Shipping and offshore tax update (September 2025)

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• Brazil: New guidelines for indirect tax reporting
• Brazil: Standard reference for classifying services for e-invoicing
• Colombia: Resolution consolidating and clarifying regulations under jurisdiction of tax authority
• Dominican Republic: Tax measures to support waste management passed by lower house of Parliament
• KPMG report: Shipping and offshore tax update (September 2025)
• Mexico: Alternative dispute resolution (ADR) mechanisms for resolving tax disputes
• Mexico: Draft decree amending tax controversy rules
• OECD: Argentina submits instrument of ratification for BEPS Convention

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• Australia: Excise tax guidelines for tobacco industry and duty-free shops
• Australia: Government report and issue papers from strategic examination of R&D system
• Australia: Guidance on thin capitalization rules
• Australia: Invitation for expressions of interest for large business stewardship group
• China: Consumption tax threshold for super luxury cars reduced
• India: Unabsorbed depreciation carried over may be used even if no business activity in later tax year (tribunal decision); other direct and indirect tax developments
• Indonesia: Income tax withholding obligations for e-commerce platforms and online marketplaces
• Korea: Royalties from patents not registered in Korea may be subject to tax in Korea under U.S. treaty (Supreme Court decision); other tax developments
• KPMG report: Shipping and offshore tax update (September 2025)
• Kuwait: Electronic registration service for companies subject to domestic minimum top-up tax (DMTT) launched
• Malaysia: Guidance on sales tax exemption for raw materials, components, packing and packaging materials, manufacturing aids, and cleanroom equipment
• Malaysia: Guidance on sales tax exemptions
• Saudi Arabia: Mandatory e-invoicing for taxpayers with revenue above SAR 375,000
• Singapore: Guidance on stamp additional conveyance duties on property-holding entities
• Sri Lanka: Notices in relation to simplified VAT scheme published
• UAE: Framework, scope, and implementation of e-invoicing system
• UAE: Updated guide on VAT input tax apportionment

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• Belgium: Annulment of key provisions of Cayman Tax 2.1 (Constitutional Court decision)
• Belgium: Boundaries of tax investigations and data requests (Court of Appeal decision)
• Belgium: Indefinite postponement of modernization of VAT rules
• Belgium: Transfer pricing dispute concerning royalties, factoring fees, and interest deductions (court decision)
• EU: CJEU referral on tax treatment of distributions made by private foundations to nonresident beneficiaries (Austria)
• EU: CJEU referrals on third-party liability for VAT debts of dissolved company, classification of decorative infused paper sheets under combined nomenclature (Bulgaria)
• EU: Update on European Trust and Cooperation Approach to transfer pricing, BEFIT proposal, creation of Capital Markets Union
• France: Proposed simplification and tolerance measures for e-invoicing and e-reporting reform
• Germany: Draft amendments to Pillar Two rules adopted by Federal Cabinet; draft bill to implement DAC8; other tax developments
• Hungary: Carbon border adjustment mechanism (CBAM) authorization procedure launched
• KPMG report: Shipping and offshore tax update (September 2025)
• Netherlands: Interest rate on corporate income tax due found contrary to principle of proportionality (Supreme Court Advocate General opinion)
• Poland: Company formed by local government not VAT payer; excise duty exemption depends on rate applicable when energy produced (Supreme Administrative Court decisions)
• Poland: Leased passenger cars subject to new cap on tax-deductible costs, regardless of when contract concluded
• Poland: Proposed amendments to direct and indirect tax laws
• Slovakia: Draft amendments to VAT law submitted to Parliament
• Slovakia: Third package of consolidation measures approved by Parliament
• Spain: Arm’s length remuneration in cash pooling arrangements of multinational groups (Supreme Court decision)
• Sweden: Proposed changes to targeted interest deduction limitation rules
• Switzerland: GloBE reporting regulations adopted by Federal Council
• UK: HMRC guidance on new reserved investor fund

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

• BEPS
• Indirect Tax
• Digital Economy
• Tax Controversy