KPMG Week in Tax: November 3 – 7, 2025

Recent tax developments from around the globe for the week of November 3 – 7, 2025

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november 10, 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).

  • Canada: The 2025 federal budget maintains current individual and corporate tax rates but introduces immediate expensing for manufacturing buildings, expands scientific research and experimental development (SR&ED) and clean economy tax credits, and modernizes transfer pricing rules. The budget also streamlines savings plans, strengthens anti-avoidance measures, eliminates the underused housing tax, and repeals the luxury tax on certain aircraft and vessels. Read TaxNewsFlash
  • Brazil: The Senate has approved a 10% withholding tax on dividends paid to foreign parties, effective for fiscal years starting January 1, 2026, with limited exemptions and a potential tax credit mechanism. This change increases costs for multinationals, introduces uncertainty around double taxation and cash flow, and raises questions about alignment with Brazil’s transfer pricing rules and treaty network. Read TaxNewsFlash
  • United States: As part of a trade and economic agreement between the United States and China (read TradeNewsFlash):
    • China committed to eliminate export controls, halt fentanyl precursor shipments, and suspend retaliatory tariffs and non-tariff measures.
    • The United States will lower tariffs on Chinese imports and extend tariff suspensions and exclusions. 

United States

  • Notice 2025-62: Penalty relief related to information reporting requirements for deductions for qualified tips and overtime
  • New York City: Proposed rules for business corporation tax
  • KPMG article: How do United States-Asia trade agreements affect DSTs, FDDEI and VAT?
  • KPMG article: Navigating the new 1% floor on corporate charitable deductions

Read TaxNewsFlash-United States

Transfer Pricing

  • Australia: Consultation on draft instructions for public country-by-country (CbC) report
  • Brazil: Transfer pricing implications of proposed 10% dividend withholding tax for MNEs
  • Canada: Direct and indirect tax measures in 2025 federal budget, including amendments to modernize transfer pricing rules
  • Channel Islands: Initial Pillar Two guidance (Guernsey)
  • EU: Challenge to EU minimum tax directive on standing grounds (CJEU judgment)
  • Israel: Final guidance regarding local R&D centers and IP valuations
  • Italy: GloBE information return (GIR) and filing instructions
  • Japan: Guidance on amendments to IIR and CFC regime under 2025 tax reform
  • Mauritius: QDMTT notification platform open, deadline for notifications extended to November 30

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Antigua and Barbuda: Recent guidance under CRS regime
  • Barbados: AEOI reporting portal reopens for amendments to prior-year reports
  • Finland: Updated guidance on negligence fees for third-party declarants
  • Luxembourg: Updated CRS guidance
  • South Africa: Draft business requirement specifications for FATCA, CRS, and CARF
  • South Africa: Removal from Financial Action Task Force “grey list”
  • UK: Updated guidance on AEOI reporting and account holders compliance

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • U.S. State Department lifts defense trade embargo on Cambodia under International Traffic in Arms Regulations
  • United States and China reach trade and economic deal
  • United States modifies tariff rates and duties on China following trade and economic deal
  • USTR requests comments on proposed suspension of Section 301 actions targeting China’s maritime, logistics, and shipbuilding sectors

Read TradeNewsFlash-Trade & Customs

Africa

  • Mauritius: QDMTT notification platform open, deadline for notifications extended to November 30
  • Nigeria: Transition to new economic development tax incentive scheme
  • South Africa: Tax implications of introduction of ZARONIA as key reference interest rate

Read TaxNewsFlash-Africa

Americas

  • Argentina: New digital tool for exporters
  • Brazil: Transfer pricing implications of proposed 10% dividend withholding tax for MNEs
  • Canada: Direct and indirect tax measures in 2025 Fall Economic Update (Ontario)
  • Canada: Direct and indirect tax measures in 2025 federal budget, including amendments to modernize transfer pricing rules
  • Costa Rica: Mandatory reporting of transactions not supported by electronic vouchers

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Consultation on draft instructions for public country-by-country (CbC) report
  • Australia: Consultation on draft legislation providing New Zealand wine exporter producer rebate
  • Australia: Legislation extending instant asset write-off for one year, expanding beneficial ownership disclosure obligations referred to Senate Committee
  • Australia: Redesigned Voluntary Tax Transparency Code (VTTC)
  • Israel: Final guidance regarding local R&D centers and IP valuations
  • Israel: Highlights of high-tech tax reform proposals
  • Japan: Guidance on amendments to IIR and CFC regime under 2025 tax reform
  • Qatar: Change to withholding tax declaration process via tax portal

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Rents paid to foreign companies exempt from withholding tax
  • Channel Islands: Initial Pillar Two guidance (Guernsey)
  • EU: Amendments to carbon border adjustment mechanism (CBAM) regulation
  • EU: Challenge to EU minimum tax directive on standing grounds (CJEU judgment)
  • Italy: GloBE information return (GIR) and filing instructions
  • Poland: Meaning of “turnover” under VAT margin scheme; VAT on free-of-charge transfer of real estate; remote work does not create PE; cooperation agreement does not create related entities
  • Poland: Proposed increased VAT rate on non-alcoholic and energy drinks, reduced tax on extraction of certain minerals
  • Serbia: Public consultation on draft law on fees for use of public resources
  • Spain: Beneficial ownership requirement inapplicable to domestic interest exemption (court decision)

Read TaxNewsFlash-Europe

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