KPMG Week in Tax: December 8 – 12, 2025

Recent tax developments from around the globe for the week of December 8 – 12, 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 and proposed regulations relate to the taxation of income of foreign (non-U.S.) governments and international organizations from investments in the United States. The regulations clarify when income from U.S. investments by non-U.S. governments and international organizations is exempt from U.S. tax, with updated definitions of commercial activity, controlled commercial entities, and partnership rules, as well as new guidance on debt investments and effective control. Read TaxNewsFlash
Colombia: The Senate has rejected the government’s proposed tax reform, which included higher income and dividend taxes, a new wealth tax, and broader rules for digital assets and permanent establishments. Read TaxNewsFlash
Switzerland: Proposed value added tax (VAT) law amendments would lower the threshold for bundled offerings, extend platform taxation to digital services (making platforms responsible for VAT collection), and grant tax authorities new enforcement powers, including website blocking for non-compliance. The public consultation period is open until March 19, 2026. Read TaxNewsFlash

United States

Final and proposed regulations: Income of non-U.S. governments and of international organizations under section 892
Proposed regulations: Updating regulation references to reflect reorganizations at DOJ and IRS
Proposed regulations withdrawn: Relief from joint and several liability
Notice 2026-5: Guidance on expanded HSA eligibility under OBBBA
Rev. Rul. 2026-1: Covered compensation tables for 2026 plan year
DOJ transfers tax division functions to civil and criminal divisions
IRS announces tax relief for taxpayers affected by storms (Leech Lake Band of Ojibwe Tribal Nation)
FBAR filings: Extended deadline is April 15, 2027, for individuals with signature authority

Read TaxNewsFlash-United States

Exempt Organizations

Rev. Proc. 2026-6: Advance election for new tax credit for individual contributions to scholarship granting organizations

Read TaxNewsFlash-Exempt Organizations

Transfer Pricing

Australia: ATO administrative approach to public country-by-country reporting exemptions
Australia: Proposed changes to transfer pricing guidance for inbound distributors
Germany: Obligation to disclose emails in tax audits (court decision)
India: “At-cost” transfer pricing model upheld for provision of technical services in oil and gas operations (tribunal decision)
KPMG article: Survey on application of control of risk and DEMPE frameworks, focus on Switzerland
KPMG report: Transfer pricing implications of CJEU judgment on application of VAT to cross-border intra-group services
Singapore: Legislative changes focus on Pillar Two

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Brazil: Implementation of DeCripto for cryptoasset reporting under CARF
Finland: Proposed implementation of DAC8, CARF, and CRS 2.0
South Africa: Implementation of cryptoasset reporting framework (CARF) and CRS amendments
United States: IRS updates FATCA guidance extending penalty relief
United States: Scheduled maintenance for FATCA Registration System begins December 24
Uruguay: Proposed CRS 2.0 amendments

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

Canada: Temporary remission of tariffs on certain steel imports to end January 31, 2026
Costa Rica and Israel sign free trade agreement
Mexico: Extension of transition period for value declaration; proposed import tariffs
U.S. BIS renews temporary denial order for Russian airline
USTR announces phased-in tariff on imported Nicaraguan goods

Read TradeNewsFlash-Trade & Customs

Africa

Cameroon: Significant economic presence standard introduced from 2026
Nigeria: Tax Appeal Tribunal affirms authority to grant interim and interlocutory reliefs in tax disputes

Read TaxNewsFlash-Africa

Americas

Antigua and Barbuda: Planned e-invoicing system to enhance tax compliance
Colombia: Senate rejects proposed tax reform bill
Costa Rica: Adjustment of VAT reporting to minimize accounting impact from contingency measures
Costa Rica: Guidelines for application of fiscal stamp
Mexico: Extension of transition period for value declaration; proposed import tariffs
Mexico: Modifications to payroll electronic invoices (CFDI)

Read TaxNewsFlash-Americas

Asia Pacific

Australia: ATO administrative approach to public country-by-country reporting exemptions
Australia: Pre-capital gains tax status can be retained when shares are held through discretionary trust (Administrative Review Tribunal decision)
Australia: Proposed changes to transfer pricing guidance for inbound distributors
India: “At-cost” transfer pricing model upheld for provision of technical services in oil and gas operations (tribunal decision)
India: Dividend distribution tax cannot exceed tax treaty rate (High Court decision)
India: Physical presence required for service PE under India-Singapore treaty (court decision)
Israel: Expansion of mandatory e-invoicing model
Malaysia: Stamp assessment and payment system replaced by e-Duti Setem starting January 1, 2026
Malaysia: Tax developments summary (December 2025)
Singapore: Legislative changes focus on Pillar Two
Singapore: Updates to tax guidance and e-Tax Guides

Read TaxNewsFlash-Asia Pacific

Europe

Bosnia and Herzegovina: Updated withholding tax obligations and forms
Cyprus: Deadline extended to submit employers’ income tax withholding declaration for 2024
Cyprus: Extension of zero VAT rate on certain goods; reduced VAT rate for educational buildings
Czech Republic: Changes in R&D allowances effective January 1, 2026
Czech Republic: Documentation requirements for tax-deductible depreciation of real estate improvements (Supreme Administrative Court decision)
France: Senate approves tax treaty with Finland, protocol to tax treaty Sweden
Germany: Input tax deduction in absence of tax statement; other VAT developments
Germany: Obligation to disclose emails in tax audits (court decision)
Greece: New super-deduction tax incentives for defense sectors and manufacturing of vehicles, aircraft
KPMG report: Transfer pricing implications of CJEU judgment on application of VAT to cross-border intra-group services
Serbia: Amendments to individual income tax and social security contributions
Serbia: Amendments to VAT law adopted
Serbia: New green taxes effective January 1, 2026
Switzerland: Proposal to expand VAT platform taxation rules to digital services
UK: Tax measures in Finance Bill 2025-2026

Read TaxNewsFlash-Europe

Other publications

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

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

Relevant Results