KPMG Week in Tax: November 24 – December 5, 2025

Recent tax developments from around the globe for the weeks of November 24 – December 5, 2025

Share
december 8, 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).

  • UK: The Autumn Budget 2025 introduced a broad range of tax measures, including changes to corporation tax rates, capital allowances, transfer pricing, R&D incentives, and digital services tax, alongside reforms affecting multinational taxation, VAT, and sector-specific duties. Read TaxNewsFlash
  • United States: Notice 2025-72 announced (1) that proposed regulations under section 898 will address the allocation of taxes of foreign corporations affected by the repeal of the one-month deferral election, and (2) that proposed regulations under section 987 will modify the election to recognize pretransition section 987 gain or loss ratably over the transition period pursuant to §1.987-10(e)(5)(ii)(A). Read TaxNewsFlash
  • Singapore: Updated transfer pricing guidelines introduced key updates on the treatment and annual review of domestic related-party loans, authority to recharacterize or disregard funding arrangements, simplified documentation requirements, and the pilot implementation of Amount B under Pillar Two. Read TaxNewsFlash

United States

  • KPMG article: Update to prefiling agreement program
  • KPMG report: 2025 state R&D credit changes
  • KPMG report: Guidance on allocation of foreign income taxes and section 987 transition rules (Notice 2025-72)
  • Notice 2025-60: Required amendments list (2025) for qualified retirement plans and 403(b) plans
  • Notice 2025-68: Intent to issue proposed regulations regarding “Trump accounts”
  • Notice 2025-70: Request for comments on implementation of individual tax credit for qualifying contributions to scholarship granting organizations under section 25F
  • Notice 2025-72: Intent to issue proposed regulations on repeal under OBBBA of one-month deferral election under section 898(c)(2)
  • Notices 2025-75, 2025-77, and 2025-78: Intent to issue proposed regulations regarding various international tax provisions of OBBBA
  • Overview of the latest state-by-state changes to the R&D credit
  • Tier 2 tax rates for railroads, no changes for 2026

Read TaxNewsFlash-United States

  • House passes two bills aimed at improving tax administration
  • President Trump signs into law IRS Math and Taxpayer Help Act

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Australia: Guidance on Pillar Two filing obligations
  • Australia: Sample combined Pillar Two return forms
  • Costa Rica: Updates to TRIBU-CR system for excise taxes, real estate capital gains withholding, and transfer pricing return due dates
  • Germany: Amendments to Pillar Two rules passed by lower house of Parliament; draft DAC9 legislation submitted to upper house of Parliament; other tax developments
  • Honduras: Country-by-country report notification due December 31, 2025
  • Hungary: Autumn tax package adopted, including changes to global minimum tax rules
  • Hungary: Proposed changes to transfer pricing documentation and data disclosure
  • KPMG article: OECD’s 2024 APA statistics report
  • Netherlands: 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9
  • OECD: Public consultation on tax issues relevant to global mobility of individuals
  • OECD: Report to G20 leaders on international tax cooperation, G20 leaders’ declaration on Pillar Two
  • Singapore: Updated transfer pricing guidelines include pilot implementation of Pillar Two Amount B
  • UK: Tax measures in Autumn Budget 2025 include changes to Pillar Two rules and transfer pricing, DST, and DPT reform
  • Uruguay: Proposed amendments to budget proposals, including Pillar Two minimum tax

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Barbados: Further extension of FATCA and CRS filing deadline to December 12, 2025
  • Barbados: Guidance on FATCA and CRS procedural manual requirements
  • Barbados: Updated CRS frequently asked questions (FAQs)
  • Colombia: Proposed implementation of OECD cryptoasset reporting framework (CARF)
  • Germany: Guidance on transition from ELAN to POSt for FATCA reporting
  • Panama: Guidance on FATCA, CRS, and portal registration
  • Sweden: Updated lists of reportable and participating jurisdictions for automatic exchange of financial account information
  • Switzerland: Amendments to AEOI legislation to incorporate CARF and CRS 2.0
  • UK: Guidance on cryptoasset reporting framework (CARF)

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • EU revises Generalised Scheme of Preferences (GSP)
  • Mexico: Reforms to customs law
  • Nigeria: Guidance on withholding tax on interest from short-term securities; duty-free threshold for low-value imports; tax administration reform
  • Romania: Proposed logistics tax on certain goods from outside EU
  • U.S. BIS renews temporary denial of export privileges for Russian airline
  • U.S. OFAC imposes $7.1 million penalty on property management company for sanctions violations
  • U.S. tariff modifications on products from Korea
  • USTR extends product exclusions related to China Section 301 tariffs
  • USTR request for comments on United States-Mexico-Canada Agreement (USMCA) automotive goods trade

Read TradeNewsFlash-Trade & Customs

Africa

  • Nigeria: Guidance on withholding tax on interest from short-term securities; duty-free threshold for low-value imports; tax administration reform
  • South Africa: Draft guidance on income tax exemption
  • Zimbabwe: Direct and indirect tax proposals in 2026 budget

Read TaxNewsFlash-Africa

Americas

  • Antigua and Barbuda: Termination of all existing tax concessions from November 30, 2025
  • Argentina: Recent indirect tax developments
  • Brazil: Dividend withholding tax and refund mechanism for foreign investors
  • Canada: Proposed tax measures in 2025 fall economic update (Quebec)
  • Chile: Tax compliance confirmation process for platforms and payment service providers
  • Colombia: Proposed implementation of OECD cryptoasset reporting framework (CARF)
  • Colombia: Second extension of deadline to apply for tax benefits involving renewable energy projects
  • Costa Rica: Amendments to simplified tax regime regulations
  • Costa Rica: Reduced excise taxes on beverages and perfumed soap
  • Costa Rica: Updates to TRIBU-CR system for excise taxes, real estate capital gains withholding, and transfer pricing return due dates
  • Honduras: Country-by-country report notification due December 31, 2025
  • Mexico: Reforms to customs law
  • Saint Vincent and the Grenadines: Various direct and indirect tax rate cuts announced
  • Uruguay: Proposed amendments to budget proposals, including Pillar Two minimum tax
  • Uruguay: Temporary VAT exemption for certain tourism services

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Amendments to omnibus bill passed by Parliament, received Royal Assent (Victoria)
  • Australia: Beneficial ownership, instant asset write-off bill passes parliament
  • Australia: Beneficial ownership, instant asset write-off bill receives Royal Assent
  • Australia: Consultation on operation of 2018 GST reforms
  • Australia: Guidance on Pillar Two filing obligations
  • Australia: Income tax treaty with Croatia signed
  • Australia: Sample combined Pillar Two return forms
  • Georgia: Protocols to income and capital tax treaties with San Marino and Luxembourg ratified
  • Hong Kong: Management fees paid to BVI affiliate not deductible (Court of Appeal decision)
  • India: Deduction of payments for intercompany advisory and business support services allowed (High Court decision)
  • India: Income tax treaty with Qatar enters into force
  • India: Taxpayer allowed foreign tax credits on income not taxable under Japan treaty (tribunal decision); other direct and indirect tax developments
  • Kazakhstan: New CFC forms; new whitelist of countries not considered to have preferential tax regimes
  • Kazakhstan: Rules for determining taxable income from banking activities
  • Oman: Draft data dictionary for e-invoicing
  • Philippines: Simplified tax framework for metallic mining
  • Singapore: Updated transfer pricing guidelines include pilot implementation of Pillar Two Amount B
  • Sri Lanka: Proposed amendments to tax incentives and exemptions (Colombo Port City)
  • Sri Lanka: Tax exemptions and deferments due to Cyclone Ditwa
  • Taiwan: Guidance on foreign currency gains and losses, earnings declarations

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Draft law confirms e-invoicing grace period and clarifies the scope of mandate for nonresidents
  • Belgium: Tax measures in budget framework 2026-2029
  • Belgium: Three-month tolerance period for e-invoicing mandate effective January 1, 2026
  • Czech Republic: Taxpayer not entitled to reduce tax base because change in accounting method not proven (Supreme Administrative Court decision)
  • Denmark: Tax incentive proposals in 2026 Finance Bill
  • Estonia: Draft amendments to motor vehicle tax adopted by Parliament; other draft income and gambling tax amendments
  • EU: CJEU judgment on compatibility with EU law of evidentiary requirements for nonresident pension funds seeking withholding tax exemption (Portugal)
  • EU: CJEU referral on whether sale of real property qualifies as transfer of going concern for VAT purposes (Netherlands)
  • EU: CJEU rejects appeal from General Court decision that Madeira Free Zone scheme not implemented in line with approved conditions (Portugal)
  • EU: Triangulation simplification applies beyond three parties in EU VAT supply chains
  • Georgia: Protocols to income and capital tax treaties with San Marino and Luxembourg ratified
  • Germany: Amendments to Pillar Two rules passed by lower house of Parliament; draft DAC9 legislation submitted to upper house of Parliament; other tax developments
  • Germany: Draft legislation extending vehicle tax exemption for electronic vehicles
  • Germany: Pending protocols to income tax treaties with the Netherlands and Switzerland approved by lower house of Parliament
  • Greece: Super-deduction regime to support investment in defense-related and allied manufacturing units
  • Hungary: Autumn tax package adopted, including changes to global minimum tax rules
  • Hungary: Proposed changes to transfer pricing documentation and data disclosure
  • Latvia: Partial implementation of reporting obligations for cryptoasset service providers (DAC8)
  • Lithuania: Amendments to corporate income tax, VAT, excise taxes, and real estate tax, introduction of insurance premium tax
  • Moldova: Clarifications on VAT on vending machines and application of accelerated depreciation
  • Moldova: Constitutional Court upholds VAT refund regulation
  • Netherlands: 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9
  • Poland: Employee income from accident insurance; “first occupancy” under VAT Act; partnership filing obligation (Supreme Administrative Court decisions)
  • Poland: Legislation passed by upper house of Parliament includes direct and indirect tax changes
  • Poland: Management fees not eligible for tax exemption; residential building not subject to property tax rate for premises used for business purposes (Supreme Administrative Court decisions)
  • Portugal: Postponed mandatory use of qualified electronic signature (QES) and SAF-T accounting file requirements
  • Romania: Proposed logistics tax on certain goods from outside EU
  • Slovakia: Amendment to Financial Transaction Tax Act introduces new rules
  • Spain: Extension to nonresidents of wealth tax liability limitation based on income (Supreme Court decisions)
  • Spain: VERI*FACTU invoicing system delayed to 2027
  • Sweden: Parliament approves amendments to interest deduction limitation rules
  • Sweden: Tax measures in 2026 budget bill includes labour tax reductions, lower VAT on food
  • Switzerland: Extension of withholding tax exemption on "too-big-to-fail" instruments approved by National Council
  • Ukraine: Expanded scope of Diia City tax incentive regime
  • Ukraine: Notification of updates to MLI positions
  • UK: Guidance on cryptoasset reporting framework (CARF)
  • UK: Tax measures in Autumn Budget 2025 include changes to Pillar Two rules and transfer pricing, DST, and DPT reform

Read TaxNewsFlash-Europe

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.

KPMG. Make the Difference.


Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

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 upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

© 2025 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP's . Privacy Statement

An error occurred. Please contact customer support.

Job seekers

Visit our careers section or search our jobs database.

Search now!

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Submit

Office locations

View locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Learn more

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Contact

Headline