KPMG Week in Tax: November 10 – 14, 2025

Recent tax developments from around the globe for the week of November 10 – 14, 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).

Australia: The Australian Taxation Office has extended the filing deadline for country-by-country (CbC) reporting entities with reporting periods ending December 31, 2024, from December 31, 2025, to January 30, 2026. Read TaxNewsFlash
EU: The Economic and Financial Affairs Council (ECOFIN) agreed to remove the exemption from customs duties for goods valued under €150 entering the EU. Once the EU customs data hub launches (expected in 2028), all goods—regardless of value—will be subject to customs duties. Read TaxNewsFlash
United States: Congress passed a continuing resolution to fund the federal government through January 30, 2026. As a result, nearly 50% of furloughed IRS employees will return to work, and recent reduction in force notices—including those affecting over 1,400 IRS staff—will be rescinded, with new layoffs prohibited through January 30, 2026. Read TaxNewsFlash
United States: The White House announced the frameworks for trade deals with Argentina, Ecuador, El Salvador, Guatemala, Korea, Liechtenstein, and Switzerland, which include commitments to refrain from discrimination against U.S. digital services or products. Read TaxNewsFlash

United States

Notice 2025-65: Indexing factor for use by group health plans and health insurance issuers in 2026 under “No Surprises Act” provisions
Notice 2025-67: Increased retirement plan contribution limits for 2026
Rev. Proc. 2025-31: Safe harbor for investment and grantor trusts to stake digital assets
Rev. Rul. 2025-22: Interest rates, tax underpayments and overpayments remain same for first quarter 2026
U.S. Tax Court: Application of codified economic substance doctrine under section 7701(o) requires threshold “relevancy” determination
U.S. Tax Court: Taxpayer’s elections under section 172(b)(3) did not relinquish carryback of specified liability loss
Trade agreement frameworks with Argentina, Ecuador, El Salvador, Guatemala, Korea, and Liechtenstein and Switzerland include commitments to refrain from discrimination against U.S. digital services or products
Government reopens, IRS becomes fully operational
KPMG article: Postfiling update on dispute prevention and resolution options

Read TaxNewsFlash-United States

Transfer Pricing

Australia: Country-by-country reporting deadline extended to January 30, 2026
Austria: Draft Tax Amendment Act 2025 includes implementation of DAC9, incorporation of OECD Pillar Two administrative guidance; other recent tax developments
Cayman Islands: New country-by-country (CbC) reporting portal launched, re-registration required
Czech Republic: Draft policy statement of incoming government coalition includes mandatory transfer pricing documentation
Kazakhstan: Amendments to transfer pricing framework
Romania: Amendments to Pillar Two rules
Spain: Three new Pillar Two forms approved
Switzerland: Application of Pillar Two rules to hybrid arbitrage arrangements under CbC reporting safe harbor
UK: HMRC’s transfer pricing settlement policy

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Australia: Updated guidance on extension of temporary relief for missing U.S. TINs
Luxembourg: Updated CRS FAQs
Singapore: Updated FAQs, compliance e-tax guide, and e-tax guide under CRS
Switzerland: Consultation on protocol amending AEOI agreement with EU
Switzerland: Postponement of review of draft law introducing cryptoasset reporting framework (CARF)

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

U.S. BIS removes entity, aliases from Entity List
U.S. BIS renews temporary export denial order for Russian airline
U.S. BIS suspends expansion of end-user controls
U.S. trade agreement frameworks with Argentina, Ecuador, El Salvador, and Guatemala
United States and Korea announce trade deal framework
White House announces framework for U.S. trade deal with Liechtenstein and Switzerland
USTR suspends Section 301 actions targeting China’s maritime, logistics, and shipbuilding sectors

Read TradeNewsFlash-Trade & Customs

Africa

Botswana: Amendments to VAT law enacted
Ghana: Mandatory use of fiscal electronic devices beginning early 2026
South Africa: Compliance requirements for income transfers by residents to nonresidents
South Africa: Tax incentive for energy-efficiency savings extended through 2030

Read TaxNewsFlash-Africa

Americas

Anguilla: Implementation of general services tax on broad range of services
Argentina: Tax collection measures for non-profits suspended; tax exemptions and incentives related to mutual guarantee contracts maintained
Cayman Islands: New country-by-country (CbC) reporting portal launched, re-registration required
Chile: Adjusted excise tax rates on fuels
Mexico: Tax provisions affecting digital platforms in 2026 tax reform
Mexico: Updates to electronic invoicing (CFDI) included in 2026 tax reform
Mexico: Various direct and indirect tax amendments; new tax benefits in Yucatán
Panama: Amended criteria for using free e-invoicing service
Uruguay: Deductibility of directors' fees for corporate income tax purposes
Uruguay: Proposed tax incentives to promote investment
KPMG report: Shipping and offshore tax update (November 2025)

Read TaxNewsFlash-Americas

Asia Pacific

Australia: Country-by-country reporting deadline extended to January 30, 2026
Australia: Draft ruling restricts deductions for short-term rental properties
Cambodia: Mandatory e-invoicing expanded to six additional ministries
China: New VAT refund policy
Hong Kong: Launch of digital certificate of resident status
Indonesia: Updated tax rates for cryptoasset transactions
Kazakhstan: Amendments to transfer pricing framework
Kazakhstan: New VAT rules for foreign internet companies effective January 1, 2026
Malaysia: Tax developments summary (November 2025)
Pakistan: Withholding tax and filing requirements for digitally ordered goods
Singapore: Guidance on completing GST returns, cancelling GST registrations
Singapore: Guidance on foreign-sourced capital gains and interest income
Sri Lanka: Budget 2026 tax proposals
Sri Lanka: Proposed changes to tax holidays, exemptions, and concessions for strategic investments
Taiwan: Reminders related to claw back of retained earnings tax incentive, controlled foreign company rules
KPMG report: Shipping and offshore tax update (November 2025)

Read TaxNewsFlash-Asia Pacific

Europe

Austria: Draft Tax Amendment Act 2025 includes implementation of DAC9, incorporation of OECD Pillar Two administrative guidance; other recent tax developments
Bosnia and Herzegovina: Tax incentives for employers to maintain employment levels
Czech Republic: Draft policy statement of incoming government coalition includes mandatory transfer pricing documentation
Czech Republic: Treatment as “building land” for VAT purposes; taxation of income from sale of shares in domestic real estate company under Cyprus treaty (Supreme Administrative Court decisions)
Czech Republic: Updated guidance on direct and indirect tax obligations of entities providing transport services via mobile applications
EU: Agreement to repeal small consignments import relief
EU: CJEU Advocate general opinion on treatment of separate legal entities as single taxable person for VAT purposes (Czech Republic)
EU: CJEU Advocate General opinion that VAT margin scheme applies to artwork sales by legal entities (France)
EU: CJEU judgment that export procedure for construction materials violated EU law (Hungary)
EU: CJEU judgments on denial of VAT deduction for nonexistent transaction, taxation of VAT refund administration services (Hungary)
EU: CJEU referral on classification for customs purposes of acid-treated and industrial-use fish under combined nomenclature
France: Foreign exchange losses related to dividends under participation exemption are fully deductible (Supreme Court decision)
Germany: Taxpayer not required to confirm validity of VAT identification number in advance of every transaction; other VAT developments
Moldova: VAT liability under long-term contracts arises at date of invoice
North Macedonia: Pilot phase of e-invoicing to begin January 1, 2026
Romania: Amendments to Pillar Two rules
Romania: Draft laws propose direct and indirect tax changes
Slovakia: Expanded scope of binding tax opinions on income tax, VAT, and financial transaction tax
Spain: Three new Pillar Two forms approved
Switzerland: Application of Pillar Two rules to hybrid arbitrage arrangements under CbC reporting safe harbor
UK: HMRC’s transfer pricing settlement policy
KPMG report: Shipping and offshore tax update (November 2025)

Read TaxNewsFlash-Europe

Other publications

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

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