KPMG Week in Tax: November 17 – 21, 2025

Recent tax developments from around the globe for the week of November 17 – 21, 2025

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november 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: Final regulations clarifying the 1% excise tax on corporate stock repurchases made after December 31, 2022, include key exceptions and remove certain proposed rules that would have broadened the tax’s scope. These regulations, effective November 24, 2025, provide certainty for corporations regarding compliance and reporting, with notable carve-outs for preferred stock, complete liquidations, certain reorganizations, and specific fund types. Read TaxNewsFlash
  • United States: The IRS issued guidance for individuals claiming new federal deductions for qualified tips and overtime pay under the “One Big Beautiful Bill Act,” with no changes required to 2025 Forms W-2 or 1099. For tax years 2025–2028, eligible workers may deduct up to $25,000 in tips and up to $12,500 in overtime ($25,000 for joint filers), subject to income phaseouts, with updated IRS forms and instructions forthcoming for the filing season. Read TaxNewsFlash
  • Portugal: The corporate income tax rate will be reduced from 20% to 17% by 2028, with rates dropping to 19% in 2026 and 18% in 2027. For small and medium-sized businesses in qualifying sectors, the rate on the first €50,000 of taxable income will decrease to 15% starting in 2026, with a 17% rate applying to income above that threshold. Read TaxNewsFlash
  • Cayman Islands: A new portal for country-by-country (CbC) tax reporting requires all multinational groups with Cayman entities to re-register by November 30, 2025. Enhanced CbC reporting features and guidance will be added by November, and future communications will be limited to authorized users post re-registration. Read TaxNewsFlash

United States

  • Final regulations: Guidance on 1% excise tax on repurchases of corporate stock
  • Notice 2025-69: Guidance for individual taxpayers on deductions for qualified tips and overtime
  • Notice 2025-71: Interim guidance on tax benefit for lenders on loans secured by rural or agricultural real property under section 139L
  • California: New holder outreach to spur voluntary compliance with unclaimed property reporting requirements
  • IRS provides tax relief for taxpayers affected by storms, tornadoes, and flooding in parts of Missouri
  • KPMG article: How Generative AI may affect value chains and transfer pricing
  • KPMG article: Tariffs and advance pricing agreements (APAs)
  • KPMG article: Year-end updates and tax planning for partnerships

Read TaxNewsFlash-United States

Transfer Pricing

  • Belgium: Extended filing deadline for domestic minimum top-up tax (DMTT) return
  • India: Taxpayer treated as limited-risk distributor and use of transactional net margin method upheld (tribunal decision)
  • Italy: Filing and payment obligations for Pillar Two top-up tax
  • Japan: Overview of tax system (2025)
  • Kenya: Draft regulations proposing new framework for advance pricing agreements (APAs)
  • Liechtenstein: Additional Pillar Two registration requirement adopted
  • Malta: Guidance on automatic exchange of information (AEOI)
  • OECD: 2025 update to OECD Model Tax Convention
  • OECD: Updated list of signatories to the GloBE Information Return (GIR) MCAA
  • KPMG article: How Generative AI may affect value chains and transfer pricing
  • KPMG article: Tariffs and advance pricing agreements (APAs)
  • KPMG report: Treatment of joint ventures (JVs) under the Pillar Two model rules

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Malta: Guidance on automatic exchange of information (AEOI)
  • UAE: Commitment to implement CRS 2.0
  • UK: Updated international exchange of information manual
  • United States: Scheduled maintenance for FATCA Registration System begins November 24

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Argentina: Export rebate refund mechanisms; reduced export duties for certain oils
  • Brazil: Expansion of tax incentives for exports
  • Colombia: New customs regime proposed
  • Panama: Approval of agreement to join Mercosur
  • U.S. CBP issues withhold release order on Mauritius-based garments manufacturer
  • United States removes reciprocal tariffs on certain agricultural products
  • United States revises tariffs on Brazilian imports, exempts certain agricultural products
  • KPMG article: Tariffs and advance pricing agreements (APAs)

Read TradeNewsFlash-Trade & Customs

Africa

  • Ghana: Tax measures in 2026 budget
  • Kenya: Draft regulations proposing new framework for advance pricing agreements (APAs)
  • Mauritania: Tax provisions in Supplementary Finance Law for 2025
  • South Africa: Proposed amendments to application of “conduit principle” in relation to trust distributions

Read TaxNewsFlash-Africa

Americas

  • Argentina: Export rebate refund mechanisms; reduced export duties for certain oils
  • Brazil: Cross-border payments under agreements without technology transfer subject to 10% CIDE (Federal Supreme Court decision)
  • Brazil: Expansion of tax incentives for exports
  • Brazil: Proposed 7% digital social contribution tax
  • Colombia: Deadline extended to apply for tax benefits involving renewable energy projects
  • Colombia: New customs regime proposed
  • Mexico: List of 270 registered foreign providers of digital services (as of October 31, 2025)
  • Panama: Approval of agreement to join Mercosur

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Super funds, collective investment vehicles required to complete reportable tax position schedule for 2026
  • India: Taxpayer treated as limited-risk distributor and use of transactional net margin method upheld (tribunal decision)
  • Japan: Overview of tax system (2025)
  • Turkey: Guidance on direct and indirect taxation of sports sponsorship expenses; certain stamp duty refund claims require litigation
  • Turkey: New law includes limit on duration of corporate income tax incentives, restrictions on stamp tax exemptions for R&D personnel
  • Turkey: Revised special consumption tax rates for passenger cars and light vehicles

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Extended filing deadline for domestic minimum top-up tax (DMTT) return
  • EU: CJEU General Court judgment that Code of Conduct Group not covered by general presumption of confidentiality
  • EU: Commission paper on VAT treatment of free-of-charge access to platform in exchange for user data
  • EU: European Commission report on evaluation of DAC
  • Greece: Guidance on application of digital transaction duty
  • Greece: VAT suspension on real estate extended to December 31, 2026
  • Ireland: Guidance on application of VAT grouping rules
  • Italy: Filing and payment obligations for Pillar Two top-up tax
  • Liechtenstein: Additional Pillar Two registration requirement adopted
  • Luxembourg: Guidance clarifies VAT treatment of company cars
  • Malta: Guidance on automatic exchange of information (AEOI)
  • Poland: Continuity of business as condition for VAT exemption (Supreme Administrative Court decision)
  • Portugal: Reduction in corporate income tax rates from 20% to 17%

Read TaxNewsFlash-Europe

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