KPMG Week in Tax: December 15 – 19, 2025

Recent tax developments from around the globe for the week of December 15 – 19, 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 clarify how qualified derivative payments (QDPs) are determined and reported under base erosion and anti-abuse tax (BEAT) for securities lending transactions. The rules provide clearer definitions and two methods for identifying payments to foreign related parties. Read TaxNewsFlash
Netherlands: The upper house of Parliament has approved the entire 2026 Tax Plan, which includes significant updates such as Pillar Two changes and DAC9 implementation. Read TaxNewsFlash
Serbia: Amendments to the electronic invoicing (e-invoicing) law, effective December 12, 2025, include changes impacting retail supply, the e-invoicing system, and preliminary value added tax (VAT) returns. The new rules will apply to tax periods starting after March 31, 2026, except for preliminary tax return provisions, which are effective immediately. Read TaxNewsFlash

United States

Final regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions
Final regulations: Exclusion from gross income under section 139E of Tribal general welfare benefits
Final regulations: Federal tax classification of entities wholly owned by Indian Tribal governments
Proposed regulations: Price transparency reporting requirements for non-grandfathered group health plans
Notice 2026-1: Safe harbor for section 45Q credit for qualified carbon oxide disposed of in secure geological storage in 2025
Notice 2026-6: Extension of transition period provided in Rev. Rul. 2025-4 for state family and medical leave programs
KPMG report: Looking ahead to 2026—CAMT and asset management

Read TaxNewsFlash-United States

Transfer Pricing

Argentina: Changes to transfer pricing regimes; amendments to system for issuing receipts using “fiscal controllers”
Croatia: Amendments to local Pillar Two rules adopted
Denmark: Expanded scope of CbC reporting under DAC9; amendments to Pillar Two rules
El Salvador: Guidance on preferential tax regimes and Form F-935 for reporting withholding taxes
EU: ECOFIN approves two reports on tax-related initiatives and 2025 Code of Conduct Group conclusion
EU: Infringement procedures closed regarding Pillar Two minimum tax transposition
France: Additional Pillar Two guidance
Iceland: Budget 2026 proposes implementation of Pillar Two global minimum tax rules
Ireland: Extension of Pillar Two registration deadline
KPMG report: Implications of Zug case and Switzerland’s commitment to calendar year-based transfer pricing enforcement
Luxembourg: Overview of key tax measures for 2026
Netherlands: 2026 Tax Plan approved by upper house of Parliament, including Pillar Two changes and implementation of DAC9
Senegal: MNE groups not required to file country-by-country reports for 2023 and 2024
Turkey: Extension of QDMTT return filing deadline

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Cayman Islands: Regulations to implement CARF and CRS 2.0
Channel Islands: Draft regulations implementing cryptoasset reporting framework (Jersey)
Hungary: President signs laws ratifying multilateral agreements concerning international tax transparency

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

U.S. CBP issues withhold release order against Serbian tire manufacturer
United States revises tariffs on products from Liechtenstein and Switzerland
U.S. BIS announces inclusions window for Section 232 automobile parts tariff inclusions process
EU: Small consignments entering EU subject to fixed customs duty beginning July 1, 2026

Read TradeNewsFlash-Trade & Customs

Africa

Kenya: Five-year tax loss carryforward limit under Finance Act 2025
Kenya: Requirements for obtaining tax compliance certificate (TCC)
Kenya: VAT exemption upheld on disposal of salvage vehicles by insurers
Senegal: MNE groups not required to file country-by-country reports for 2023 and 2024
South Africa: Requirements for certain unlisted companies to qualify as a REIT
Tanzania: Tax amnesty for remission of interest and penalties
Tanzania: VAT liability upheld on performance grants (court decision)

Read TaxNewsFlash-Africa

Americas

Argentina: Changes to transfer pricing regimes; amendments to system for issuing receipts using “fiscal controllers”
Caricom: 2026 tax calendar (Barbados, Jamaica, Saint Lucia, Trinidad and Tobago)
El Salvador: Guidance on preferential tax regimes and Form F-935 for reporting withholding taxes

Read TaxNewsFlash-Americas

Asia Pacific

Armenia: Income tax treaty with Japan enters into force
India: Head office expenses and input tax credit provisions (court decisions)
Kuwait: Income tax treaty with Qatar ratified
Malaysia: Compliance review framework for e-invoicing
Sri Lanka: Postponed implementation of new VAT invoice format
Turkey: Extension of QDMTT return filing deadline
Turkey: Limited scope of simple method under individual income tax
Turkey: Tax policy reforms in medium-term program for 2026–2028
UAE: Amendments to excise tax law
UAE: Guidance on corporate tax treatment of family wealth management structures
Uzbekistan: Tax incentives for legal entities
Vietnam: Guidance on new corporate income tax law

Read TaxNewsFlash-Asia Pacific

Europe

Belgium: Law containing miscellaneous provisions approved by Parliament
Belgium: Updated draft law on new capital gains tax on financial assets
Channel Islands: Draft regulations implementing cryptoasset reporting framework (Jersey)
Croatia: Amendments to local Pillar Two rules adopted
Croatia: Amendments to VAT law adopted
Denmark: Expanded scope of CbC reporting under DAC9; amendments to Pillar Two rules
EU: ECOFIN approves two reports on tax-related initiatives and 2025 Code of Conduct Group conclusion
EU: Infringement procedures closed regarding Pillar Two minimum tax transposition
EU: Small consignments entering EU subject to fixed customs duty beginning July 1, 2026
France: Additional Pillar Two guidance
France: Mandatory POS software certification deadline postponed until September 1, 2026
Germany: Withholding tax on dividends paid by German hybrid entities
Hungary: President signs laws ratifying multilateral agreements concerning international tax transparency
Iceland: Budget 2026 proposes implementation of Pillar Two global minimum tax rules
Iceland: Guidelines on VAT obligations for cruise ship operators
Iceland: Proposed tax reform bill
Ireland: Extension of Pillar Two registration deadline
Latvia: Tax measures in 2026 budget
Luxembourg: EC launches action over dividend tax discrimination
Luxembourg: Overview of key tax measures for 2026
Netherlands: 2026 Tax Plan approved by upper house of Parliament, including Pillar Two changes and implementation of DAC9
Netherlands: Interest expenses non-deductible when debt acquisition abuses law (Supreme Court decision)
Netherlands: Internet consultation on changes to definition of mutual fund and introduction of an opt-out scheme
Netherlands: Treaty benefits under income tax treaty with Malta denied (Supreme Court decision)
Netherlands: Updated VAT decree on fuel cards and negative interest
Poland: Amendments to corporate income tax for banks and exemptions for investment funds
Poland: Senate passes amendments to cash individual income tax scheme and succession law; other tax developments
Romania: Amendments to fiscal code and introduction of new logistics fee
Romania: Compatibility of solidarity contribution with EU law (CJEU referral)
Serbia: Amendments to e-invoicing law
Serbia: Amendments to tax procedure and tax administration adopted
Serbia: Amendments to the law on electronic delivery notes
Sweden: Taxation under Sweden-UK treaty of dividends covered by UK foreign income and gains rules (Tax Court advance ruling)

Read TaxNewsFlash-Europe

Other publications

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

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