Sovereign Wealth & Pension Funds
KPMG TaxNewsFlash reports surrounding the sovereign wealth and pension funds industries
February 2025
News
President Trump orders examination of use of reciprocal tariffs
The “Fair and Reciprocal Plan” will examine non-reciprocal trade relationships with all U.S. trading partners.
News
White House announces 25% tariffs on all steel and aluminum imports
Effective March 12, 2025
News
KPMG report: Effective dates and early reliance requirements in proposed CAMT regulations
Advantages and disadvantages of early adoption of proposed regulations
News
KPMG report: Final regulations on clean hydrogen production credit and related energy credit
Initial observations and analysis on the final regulations
News
KPMG report: Partnership related-party basis adjustment transactions of interest
Reporting requirements imposed on both taxpayers and material advisors
News
White House announces directive to counter digital service taxes (DSTs)
President Trump signed a memorandum to respond to the enactment by foreign governments of DSTs.
News
White House memorandum on U.S. tax and trade policies focuses on China
Including review of whether to suspend or terminate 1984 U.S.-China income tax treaty
News
India: Proposed legislation to replace Income-tax Act, 1961
Seeks to simplify the existing tax legislation
News
India: Tax measures in budget 2025-2026
Measures related to direct and indirect tax, transfer pricing, and customs duties
News
Singapore: Tax measures in budget 2025
Includes extension and enhancement of various tax incentive schemes
News
UAE: Legislation implementing Pillar Two global minimum tax rules
Effective for financial years beginning on or after January 1, 2025
News
Belgium: “Fairness tax” compatible with EU law (CJEU judgment)
Belgium's "fairness tax" did not breach the freedom of establishment.
News
EU: Updated list of non-cooperative tax jurisdictions
No new jurisdictions were added to the list of non-cooperative jurisdictions.
News
Ireland: Updated guidance regarding controlled foreign company (CFC) rules
Incorporating changes from the Finance Act 2024
News
Netherlands: Updated guidance on tax treatment of stock options
Stock options taxed when shares become tradeable rather than an exercise
News
UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
Including incorporation of provisions from OECD June 2024 Administrative Guidance
News
UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
Last consultation before guidance manual will be published in late spring 2025
Transfer Pricing and BEPS
Trade & Customs
News
President Trump orders examination of use of reciprocal tariffs
The “Fair and Reciprocal Plan” will examine non-reciprocal trade relationships with all U.S. trading partners.
News
White House announces 25% tariffs on all steel and aluminum imports
Effective March 12, 2025
United States
News
KPMG report: Effective dates and early reliance requirements in proposed CAMT regulations
Advantages and disadvantages of early adoption of proposed regulations
News
KPMG report: Final regulations on clean hydrogen production credit and related energy credit
Initial observations and analysis on the final regulations
News
KPMG report: Partnership related-party basis adjustment transactions of interest
Reporting requirements imposed on both taxpayers and material advisors
News
White House announces directive to counter digital service taxes (DSTs)
President Trump signed a memorandum to respond to the enactment by foreign governments of DSTs.
News
White House memorandum on U.S. tax and trade policies focuses on China
Including review of whether to suspend or terminate 1984 U.S.-China income tax treaty
Americas
Asia Pacific
News
India: Proposed legislation to replace Income-tax Act, 1961
Seeks to simplify the existing tax legislation
News
India: Tax measures in budget 2025-2026
Measures related to direct and indirect tax, transfer pricing, and customs duties
News
Singapore: Tax measures in budget 2025
Includes extension and enhancement of various tax incentive schemes
News
UAE: Legislation implementing Pillar Two global minimum tax rules
Effective for financial years beginning on or after January 1, 2025
Europe
News
Belgium: “Fairness tax” compatible with EU law (CJEU judgment)
Belgium's "fairness tax" did not breach the freedom of establishment.
News
EU: Updated list of non-cooperative tax jurisdictions
No new jurisdictions were added to the list of non-cooperative jurisdictions.
News
Ireland: Updated guidance regarding controlled foreign company (CFC) rules
Incorporating changes from the Finance Act 2024
News
Netherlands: Updated guidance on tax treatment of stock options
Stock options taxed when shares become tradeable rather than an exercise
News
UK: Amendments to Pillar Two rules in amended Finance Bill 2024-2025
Including incorporation of provisions from OECD June 2024 Administrative Guidance
News
UK: Consultation on supplementary draft guidance on Pillar Two global minimum tax rules
Last consultation before guidance manual will be published in late spring 2025
January 2025
News
KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
News
OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration
Additional administrative guidance under the Pillar Two rules
News
Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One
The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.
News
Final regulations: Clean electricity production and investment credits under sections 45Y and 48E
Clean electricity production and clean electricity investment credits as established by the “Inflation Reduction Act of 2022”
News
Final regulations: Clean hydrogen production credit and related energy credit
Final regulations apply to tax years beginning after December 26, 2023
News
KPMG article: Debt workouts in commercial real estate
Tax ramifications to borrowers looking to refinance properties
News
KPMG report: Analysis and observations on investment tax credit for energy property under section 48
Rules for determining whether investments in energy property are eligible for the energy credit and for defining an energy project
News
KPMG report: Implications of Denham Capital Management LP v. Commissioner Tax Court Opinion
Partners were more akin to employees than passive investors and all the partnership allocations at issue were subject to self-employment
News
KPMG report: Initial observations on a second Trump presidency and the implications for U.S. infrastructure investment
Presidential actions and orders that may have implications for infrastructure investment in the United States
News
KPMG report: Observations on amendments to section 52 regulations as part of amendments to consolidated return regulations
Changes to the constructive ownership rules
News
KPMG report: Regulations regarding digital content and cloud transactions
Analysis and observations on the final and proposed regulations
News
Proposed regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions
Guidance under section 59A BEAT rules regarding how QDPs in connection with securities lending transactions are determined and reported
News
Treasury and IRS release guidance on clean fuel production credit under section 45Z
Guidance includes notice of intent to propose regulations and notice providing annual emissions rate table
News
White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
News
Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
Rules are effective from January 1, 2024.
News
Australia: New transfer pricing guidance on inbound related-party funding for property and construction
Guidance highlights concerns and factors that attract tax authority’s attention
News
India: Capital losses not reduced by grandfathered exempt capital gains under Mauritius treaty (Tribunal decision)
Capital losses not reduced by capital gains realized before April 1, 2017, and exempt under grandfathering provisions of India-Mauritius income tax treaty
News
India: Grandfathering provision under tax treaty is excluded from principal purpose test
Guidance clarifies the application of the principal purpose test (PPT) in Indian tax treaties with grandfathering provisions
News
Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
News
Korea: Direct and indirect tax incentives to promote foreign investment announced
Include extension of tax relief period for importation of capital goods for foreign investments by one year
News
Kuwait: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
News
Malaysia: Transfer pricing guidelines and audit framework for 2024
Guidelines are effective from year of assessment 2023, and framework is effective from December 24, 2024.
News
Oman: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
News
Thailand: Law implementing Pillar Two global minimum tax rules published
Rules became effective January 1, 2025
News
France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
News
Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
Recent tax developments in Germany
News
Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities
Reports discussing key considerations for fund vehicles and Irish securitization entities
News
KPMG article: Examination of UK’s “one-way street” transfer pricing rule
A strict “one-way street” approach may be unnecessary in light of major developments in the international tax landscape and the UK.
News
Spain: Dividend withholding tax in breach of EU law (CJEU judgment)
Spain’s dividend withholding tax rules constitute an unjustified restriction on the free movement of capital.
News
Spain: Law implementing Pillar Two global minimum tax approved
Law also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
News
Sweden: Report on government study of taxation of carried interest
Report proposes to tax carried interest under 3:12 rules effective January 1, 2026
Transfer Pricing and BEPS
News
KPMG report: Inclusive Framework guidance on application of GloBE rules
Including guidance relating to GloBE information return
News
OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration
Additional administrative guidance under the Pillar Two rules
News
Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One
The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.
Trade & Customs
United States
News
Final regulations: Clean electricity production and investment credits under sections 45Y and 48E
Clean electricity production and clean electricity investment credits as established by the “Inflation Reduction Act of 2022”
News
Final regulations: Clean hydrogen production credit and related energy credit
Final regulations apply to tax years beginning after December 26, 2023
News
KPMG article: Debt workouts in commercial real estate
Tax ramifications to borrowers looking to refinance properties
News
KPMG report: Analysis and observations on investment tax credit for energy property under section 48
Rules for determining whether investments in energy property are eligible for the energy credit and for defining an energy project
News
KPMG report: Implications of Denham Capital Management LP v. Commissioner Tax Court Opinion
Partners were more akin to employees than passive investors and all the partnership allocations at issue were subject to self-employment
News
KPMG report: Initial observations on a second Trump presidency and the implications for U.S. infrastructure investment
Presidential actions and orders that may have implications for infrastructure investment in the United States
News
KPMG report: Observations on amendments to section 52 regulations as part of amendments to consolidated return regulations
Changes to the constructive ownership rules
News
KPMG report: Regulations regarding digital content and cloud transactions
Analysis and observations on the final and proposed regulations
News
Proposed regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions
Guidance under section 59A BEAT rules regarding how QDPs in connection with securities lending transactions are determined and reported
News
Treasury and IRS release guidance on clean fuel production credit under section 45Z
Guidance includes notice of intent to propose regulations and notice providing annual emissions rate table
News
White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
Africa
Americas
Asia Pacific
News
Australia: Legislation providing details on computation of top-up tax under Pillar Two rules
Rules are effective from January 1, 2024.
News
Australia: New transfer pricing guidance on inbound related-party funding for property and construction
Guidance highlights concerns and factors that attract tax authority’s attention
News
India: Capital losses not reduced by grandfathered exempt capital gains under Mauritius treaty (Tribunal decision)
Capital losses not reduced by capital gains realized before April 1, 2017, and exempt under grandfathering provisions of India-Mauritius income tax treaty
News
India: Grandfathering provision under tax treaty is excluded from principal purpose test
Guidance clarifies the application of the principal purpose test (PPT) in Indian tax treaties with grandfathering provisions
News
Japan: Updated guidance on income inclusion rule
Income inclusion rule was amended in 2024 tax reform
News
Korea: Direct and indirect tax incentives to promote foreign investment announced
Include extension of tax relief period for importation of capital goods for foreign investments by one year
News
Kuwait: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
News
Malaysia: Transfer pricing guidelines and audit framework for 2024
Guidelines are effective from year of assessment 2023, and framework is effective from December 24, 2024.
News
Oman: Legislation implementing Pillar Two global minimum tax rules
New legislation introduces domestic minimum top-up tax (DMTT) for multinational groups
News
Thailand: Law implementing Pillar Two global minimum tax rules published
Rules became effective January 1, 2025
Europe
News
France: Form for Pillar Two reporting requirements, country-by-country notification
Pillar Two reporting requirements added to CbC notification form
News
Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
Recent tax developments in Germany
News
Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities
Reports discussing key considerations for fund vehicles and Irish securitization entities
News
KPMG article: Examination of UK’s “one-way street” transfer pricing rule
A strict “one-way street” approach may be unnecessary in light of major developments in the international tax landscape and the UK.
News
Spain: Dividend withholding tax in breach of EU law (CJEU judgment)
Spain’s dividend withholding tax rules constitute an unjustified restriction on the free movement of capital.
News
Spain: Law implementing Pillar Two global minimum tax approved
Law also includes amendments relating to corporate income tax, individual (personal) income tax, VAT, tax on financial entities, and excise duties.
News
Sweden: Report on government study of taxation of carried interest
Report proposes to tax carried interest under 3:12 rules effective January 1, 2026
December 2024
News
Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies
News
Comment period extended for proposed regulations on corporate alternative minimum tax (CAMT)
Comment period extended from December 12, 2024, to January 16, 2025
News
KPMG report: Determination under section 987 of taxable income or loss and foreign currency gain or loss with respect to a QBU
Analysis and observations of final and proposed regulations
News
KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”
The designations will cause certain contracts traded through these exchanges to be treated as section 1256 contracts.
News
KPMG report: Proposed adoption of Amount B in the United States
Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.
News
Technical corrections to proposed regulations on corporate alternative minimum tax (CAMT)
Comments on the proposed regulations are still being accepted until January 16, 2025.
News
Trump to nominate Scott Bessent as Treasury Secretary, Billy Long as IRS Commissioner
President-elect Donald Trump announced nominations for Treasury Secretary and IRS Commissioner
News
U.S. Tax Court: Active partners’ income subject to self-employment tax
The court upheld the IRS's adjustments.
News
Brazil: Key changes to tax reform bill
After approval by the Lower Chamber of Congress, the tax reform bill is now poised for presidential assent.
News
Canada: Overview of recent indirect tax changes
Summary of significant developments related to GST/HST, QST, PST, and other indirect taxes
News
Chile: Application of U.S. income tax treaty to royalties on feature film; other direct and indirect tax developments
A report discussing recent direct and indirect tax-related topics
News
Australia: Guidance on international transactions that attract scrutiny
Focus on related-party financing, transfer pricing, and thin capitalization rules
News
Australia: Guidance on thin capitalization rules, franked distributions, insurance premiums paid to nonresident insurers
Guidance includes draft income taxation ruling, draft practical compliance guideline, and draft practical compliance guideline update
News
Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
Legislation received Royal Assent on December 10, 2024.
News
China: VAT law enacted
Law becomes effective January 1, 2026
News
India: Transfer pricing rules applicable to transactions between foreign company and its Indian branch (Tribunal decision)
Rules must be applied because foreign company taxable in India only on the income of its Indian branch
News
Taiwan: Guidance on income tax withholding, non-withholding tax statements, tax calculation for foreign enterprises
Guidance from the Ministry of Finance
News
Belgium: Reformed investment deduction regime effective from 2025
Introduction of three categories of investments qualifying for a tax deduction
News
EU: Year-end overview of 2024 tax developments
And tax initiatives to pay attention to in 2025
News
Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
Tax measures effective from November 12, 2024
News
Luxembourg: Tax relief package passed by Parliament includes tax cuts for both corporate and individual taxpayers
Parliament passed three tax bills, including the Tax Relief Package.
News
Netherlands: Guidance on application of new framework for determining tax characterization of foreign legal forms
New framework will become effective January 1, 2025
News
Netherlands: Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules
In total, 11 tax bills and an amending act were passed.
News
Norway: New legislation mandates registration of beneficial owners
Starting July 31, 2025, companies and legal entities must register beneficial owners.
News
Spain: New tax on financial institutions, new excise duty on tobacco products, measures to combat VAT fraud with respect to fuels
Measures introduced by Law 7/2024, as amended by Royal Decree-Law 9/2024
United States
News
Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies
News
Comment period extended for proposed regulations on corporate alternative minimum tax (CAMT)
Comment period extended from December 12, 2024, to January 16, 2025
News
KPMG report: Determination under section 987 of taxable income or loss and foreign currency gain or loss with respect to a QBU
Analysis and observations of final and proposed regulations
News
KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”
The designations will cause certain contracts traded through these exchanges to be treated as section 1256 contracts.
News
KPMG report: Proposed adoption of Amount B in the United States
Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.
News
Technical corrections to proposed regulations on corporate alternative minimum tax (CAMT)
Comments on the proposed regulations are still being accepted until January 16, 2025.
News
Trump to nominate Scott Bessent as Treasury Secretary, Billy Long as IRS Commissioner
President-elect Donald Trump announced nominations for Treasury Secretary and IRS Commissioner
News
U.S. Tax Court: Active partners’ income subject to self-employment tax
The court upheld the IRS's adjustments.
Americas
News
Brazil: Key changes to tax reform bill
After approval by the Lower Chamber of Congress, the tax reform bill is now poised for presidential assent.
News
Canada: Overview of recent indirect tax changes
Summary of significant developments related to GST/HST, QST, PST, and other indirect taxes
News
Chile: Application of U.S. income tax treaty to royalties on feature film; other direct and indirect tax developments
A report discussing recent direct and indirect tax-related topics
Asia Pacific
News
Australia: Guidance on international transactions that attract scrutiny
Focus on related-party financing, transfer pricing, and thin capitalization rules
News
Australia: Guidance on thin capitalization rules, franked distributions, insurance premiums paid to nonresident insurers
Guidance includes draft income taxation ruling, draft practical compliance guideline, and draft practical compliance guideline update
News
Australia: Pillar Two minimum tax, public CbC reporting, and foreign residents’ capital gains withholding bills receive Royal Assent
Legislation received Royal Assent on December 10, 2024.
News
China: VAT law enacted
Law becomes effective January 1, 2026
News
India: Transfer pricing rules applicable to transactions between foreign company and its Indian branch (Tribunal decision)
Rules must be applied because foreign company taxable in India only on the income of its Indian branch
News
Taiwan: Guidance on income tax withholding, non-withholding tax statements, tax calculation for foreign enterprises
Guidance from the Ministry of Finance
Europe
News
Belgium: Reformed investment deduction regime effective from 2025
Introduction of three categories of investments qualifying for a tax deduction
News
EU: Year-end overview of 2024 tax developments
And tax initiatives to pay attention to in 2025
News
Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules
Tax measures effective from November 12, 2024
News
Luxembourg: Tax relief package passed by Parliament includes tax cuts for both corporate and individual taxpayers
Parliament passed three tax bills, including the Tax Relief Package.
News
Netherlands: Guidance on application of new framework for determining tax characterization of foreign legal forms
New framework will become effective January 1, 2025
News
Netherlands: Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules
In total, 11 tax bills and an amending act were passed.
News
Norway: New legislation mandates registration of beneficial owners
Starting July 31, 2025, companies and legal entities must register beneficial owners.
News
Spain: New tax on financial institutions, new excise duty on tobacco products, measures to combat VAT fraud with respect to fuels
Measures introduced by Law 7/2024, as amended by Royal Decree-Law 9/2024
Transfer Pricing and BEPS
Trade & Customs
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Latest tax developments from the United States and from KPMG member firms around the globe
November 2024
News
Final regulations: Recourse partnership liabilities and related party rules under section 752
Final rules adopt proposed regulations issued in December 2013
News
KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations
The Tax Court applied the strict construction rule to decide in the taxpayer’s favor.
News
KPMG report: Election results, preliminary observations regarding effect on future tax agenda
Preliminary observations regarding effect of yesterday’s election results on future tax agenda
News
Australia: Legislation implementing Pillar Two global minimum tax rules passes Senate
Two bills will return to the House of Representatives, while the other awaits Royal Assent
News
Singapore: Bills to implement global minimum tax; list of jurisdictions for exchange of CbC reports; applying for certificates of residence
Parliament passed bills to implement the multinational enterprise top-up tax and the domestic top-up tax
Transfer Pricing and BEPS
United States
News
Final regulations: Recourse partnership liabilities and related party rules under section 752
Final rules adopt proposed regulations issued in December 2013
News
KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations
The Tax Court applied the strict construction rule to decide in the taxpayer’s favor.
News
KPMG report: Election results, preliminary observations regarding effect on future tax agenda
Preliminary observations regarding effect of yesterday’s election results on future tax agenda
Asia Pacific
News
Australia: Legislation implementing Pillar Two global minimum tax rules passes Senate
Two bills will return to the House of Representatives, while the other awaits Royal Assent
News
Singapore: Bills to implement global minimum tax; list of jurisdictions for exchange of CbC reports; applying for certificates of residence
Parliament passed bills to implement the multinational enterprise top-up tax and the domestic top-up tax
Global Withholding Taxes
Summary of worldwide taxation of income and gains derived from listed securities
Download PDFOctober 2024
News
KPMG article: Potential effects of artificial intelligence on transfer pricing
An article that discusses the potential effects of artificial intelligence on transfer pricing and transfer pricing audits
News
OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
News
IRS Priority Guidance Plan for 2024-2025
The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.
News
KPMG article: New York City corporate tax regulations may deviate from state regulations
An article that discusses how the City’s update on how it may deviate from the state’s corporate tax regulations may simplify sourcing determinations for corporate taxpayers.
News
KPMG report: Analysis and observations on the proposed CAMT regulations
A report that summarizes a number of key issues from the proposed regulations and provides observations.
News
Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023
Exception from filing Form 4626 for tax year 2023
News
Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax
Officially aligns Brazil with countries that have adopted the OECD's global anti-base erosion (GloBE) rules
News
KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America
PPT provisions make testing availability of treaty benefits for holding companies more complex
Transfer Pricing and BEPS
News
KPMG article: Potential effects of artificial intelligence on transfer pricing
An article that discusses the potential effects of artificial intelligence on transfer pricing and transfer pricing audits
News
OECD: Model competent authority agreement on application of Amount B under Pillar One
Intended to assist countries in resolving potential double taxation in connection with application of Amount B when there is a bilateral tax treaty in effect
United States
News
IRS Priority Guidance Plan for 2024-2025
The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.
News
KPMG article: New York City corporate tax regulations may deviate from state regulations
An article that discusses how the City’s update on how it may deviate from the state’s corporate tax regulations may simplify sourcing determinations for corporate taxpayers.
News
KPMG report: Analysis and observations on the proposed CAMT regulations
A report that summarizes a number of key issues from the proposed regulations and provides observations.
News
Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023
Exception from filing Form 4626 for tax year 2023
Americas
News
Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax
Officially aligns Brazil with countries that have adopted the OECD's global anti-base erosion (GloBE) rules
News
KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America
PPT provisions make testing availability of treaty benefits for holding companies more complex
Asia Pacific
September 2024
News
KPMG article: Worldwide trends in transfer pricing
Case studies address common transfer pricing issues in several representative jurisdictions
News
KPMG report: Comments on EU public consultation on template and formats for public country-by-country (CbC) reports
In response to the EC consultation, KPMG firms in the EU submitted a memo with comments.
News
KPMG comments on European Commission consultation on ATAD
Evaluation of the Anti-Tax Avoidance Directive
News
Netherlands: Pension funds may qualify as special investment funds eligible for VAT exemption (CJEU judgment)
A CJEU judgment concerning whether pension funds qualify as special investment funds eligible for VAT exemption
News
UK: Compliance guidelines for dealing with transfer pricing risks
HM Revenue & Customs published compliance guidelines for dealing with transfer pricing risks.
Transfer Pricing and BEPS
News
KPMG article: Worldwide trends in transfer pricing
Case studies address common transfer pricing issues in several representative jurisdictions
News
KPMG report: Comments on EU public consultation on template and formats for public country-by-country (CbC) reports
In response to the EC consultation, KPMG firms in the EU submitted a memo with comments.
United States
Asia Pacific
Europe
News
KPMG comments on European Commission consultation on ATAD
Evaluation of the Anti-Tax Avoidance Directive
News
Netherlands: Pension funds may qualify as special investment funds eligible for VAT exemption (CJEU judgment)
A CJEU judgment concerning whether pension funds qualify as special investment funds eligible for VAT exemption
News
UK: Compliance guidelines for dealing with transfer pricing risks
HM Revenue & Customs published compliance guidelines for dealing with transfer pricing risks.
August 2024
News
KPMG report: Allocation of payments in context of distressed debt satisfaction
Why the payment ordering rules are best interpreted as inapplicable to a distressed debt satisfaction
News
U.S. Tax Court: Participation interest may constitute partnership interest regardless of subjective intent to be a partner
Tax Court held that the taxpayer did not meet its burden of proof
Transfer Pricing and BEPS
United States
News
KPMG report: Allocation of payments in context of distressed debt satisfaction
Why the payment ordering rules are best interpreted as inapplicable to a distressed debt satisfaction
News
U.S. Tax Court: Participation interest may constitute partnership interest regardless of subjective intent to be a partner
Tax Court held that the taxpayer did not meet its burden of proof
Americas
Asia Pacific
July 2024
News
Tax report to G20 Finance Ministers and Central Bank Governors; other reports on international tax reform developments
The report describes key developments in international tax reform since February 2024.
July 25, 2024
News
UN: Revised draft terms of reference for UN framework convention on international tax cooperation
A revised draft of terms of reference for a United Nations framework convention on international tax cooperation.
July 25, 2024
News
KPMG report: Transfer pricing in Brazil
A report on how multinational enterprises must quickly work to analyze and carefully document their operations for transfer pricing purposes
July 11, 2024
News
Australia: Draft legislation implementing Pillar Two global minimum tax rules introduced in Parliament
Draft legislation was referred to the Senate Economics Legislation Committee
July 9, 2024
News
Senate Finance hearing on tax incentives for economic development and financing; JCT description of present law
The Senate Finance Committee held a hearing titled “Tax Tools for Local Economic Development.”
July 30, 2024
News
Senate Majority Leader Schumer files motion to proceed on tax extenders bill
H.R. 7024, the “Tax Relief for American Families and Workers Act”
July 29, 2024
News
KPMG report: Expiring provisions in the 2025 “Tax Cliff”
Outline of many tax provisions set to expire
July 29, 2024
News
KPMG report: APMA program annual report on APA statistics for 2023
Examination of the report and insights for taxpayers
July 22, 2024
News
KPMG reports: Application of BBA centralized partnership audit regime
Partnership’s ability, or lack thereof, to pay a potential partnership-level liability determined under the BBA
July 8, 2024
News
Australia: Consultations on changes to foreign resident capital gains tax, foreign resident withholding tax regimes
Government initiated consultations on proposed changes to the foreign resident capital gains tax and withholding tax regimes
July 24, 2024
News
India: Tax measures in budget 2024-2025
No announcement regarding India’s adoption of the Pillar Two global minimum tax rules
July 24, 2024
News
Australia: Changes to non-arm’s length income provisions for superannuation funds
The changes became effective July 1, 2024, and apply from July 1, 2018.
July 9, 2024
Transfer Pricing and BEPS
News
Tax report to G20 Finance Ministers and Central Bank Governors; other reports on international tax reform developments
The report describes key developments in international tax reform since February 2024.
July 25, 2024
News
UN: Revised draft terms of reference for UN framework convention on international tax cooperation
A revised draft of terms of reference for a United Nations framework convention on international tax cooperation.
July 25, 2024
News
KPMG report: Transfer pricing in Brazil
A report on how multinational enterprises must quickly work to analyze and carefully document their operations for transfer pricing purposes
July 11, 2024
News
Australia: Draft legislation implementing Pillar Two global minimum tax rules introduced in Parliament
Draft legislation was referred to the Senate Economics Legislation Committee
July 9, 2024
United States
News
Senate Finance hearing on tax incentives for economic development and financing; JCT description of present law
The Senate Finance Committee held a hearing titled “Tax Tools for Local Economic Development.”
July 30, 2024
News
Senate Majority Leader Schumer files motion to proceed on tax extenders bill
H.R. 7024, the “Tax Relief for American Families and Workers Act”
July 29, 2024
News
KPMG report: Expiring provisions in the 2025 “Tax Cliff”
Outline of many tax provisions set to expire
July 29, 2024
News
KPMG report: APMA program annual report on APA statistics for 2023
Examination of the report and insights for taxpayers
July 22, 2024
News
KPMG reports: Application of BBA centralized partnership audit regime
Partnership’s ability, or lack thereof, to pay a potential partnership-level liability determined under the BBA
July 8, 2024
Asia Pacific
News
Australia: Consultations on changes to foreign resident capital gains tax, foreign resident withholding tax regimes
Government initiated consultations on proposed changes to the foreign resident capital gains tax and withholding tax regimes
July 24, 2024
News
India: Tax measures in budget 2024-2025
No announcement regarding India’s adoption of the Pillar Two global minimum tax rules
July 24, 2024
News
Australia: Changes to non-arm’s length income provisions for superannuation funds
The changes became effective July 1, 2024, and apply from July 1, 2018.
July 9, 2024
June 2024
News
India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)
To establish a PE, conditions outlined in applicable treaty must be met based on actual facts of the case
June 7, 2024
News
OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
News
U.S. Supreme Court: Chevron overruled
Courts will no longer be bound to uphold IRS regulations as authoritative interpretations of ambiguous provisions under the Code.
June 28, 2024
News
Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions
Regarding information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions
June 28, 2024
News
KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions
Initial analysis and observations
June 27, 2024
News
U.S. Supreme Court: Mandatory repatriation tax under section 965 held constitutional
A U.S. Supreme Court decision concerning mandatory repatriation tax under section 965.
June 20, 2024
News
Notice 2024-47: Additional limited relief from underpayment of estimated tax attributable to CAMT liability
Extends relief provided in Notice 2024-33
June 13, 2024
News
KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated June 2024)
Existing legislation and upcoming regulations under consideration
June 26, 2024
News
India: General anti-avoidance rule may apply even if not within scope of specific anti-avoidance rule (High Court decision)
High Court decision concerning application of general anti-avoidance rule within scope of specific anti-avoidance rule
June 17, 2024
News
India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)
To establish a PE, conditions outlined in applicable treaty must be met based on actual facts of the case
June 7, 2024
Transfer Pricing and BEPS
News
India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)
To establish a PE, conditions outlined in applicable treaty must be met based on actual facts of the case
June 7, 2024
News
OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
June 3, 2024
United States
News
U.S. Supreme Court: Chevron overruled
Courts will no longer be bound to uphold IRS regulations as authoritative interpretations of ambiguous provisions under the Code.
June 28, 2024
News
Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions
Regarding information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions
June 28, 2024
News
KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions
Initial analysis and observations
June 27, 2024
News
U.S. Supreme Court: Mandatory repatriation tax under section 965 held constitutional
A U.S. Supreme Court decision concerning mandatory repatriation tax under section 965.
June 20, 2024
News
Notice 2024-47: Additional limited relief from underpayment of estimated tax attributable to CAMT liability
Extends relief provided in Notice 2024-33
June 13, 2024
Asia Pacific
News
KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker, updated June 2024)
Existing legislation and upcoming regulations under consideration
June 26, 2024
News
India: General anti-avoidance rule may apply even if not within scope of specific anti-avoidance rule (High Court decision)
High Court decision concerning application of general anti-avoidance rule within scope of specific anti-avoidance rule
June 17, 2024
News
India: Mere existence of subsidiary in India does not automatically constitute a permanent establishment (High Court decision)
To establish a PE, conditions outlined in applicable treaty must be met based on actual facts of the case
June 7, 2024
May 2024
No results found.
News
Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One nearing completion
The OECD released a statement by the co-chairs of the Inclusive Framework on Base Erosion and Profit Shifting.
May 30, 2024
News
Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury on the primary legislation
May 23, 2024
News
KPMG report: Employee data reporting for public country-by-country reporting
Discusses how navigating complexities of public CbC reporting requires an understanding of nuances of employee data reporting
May 2, 2024
News
Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury on the primary legislation
May 23, 2024
News
Australia: Tax promoter bill passes Parliament
The bill proposes to improve the ability of the ATO to target promoters of tax exploitation schemes.
May 17, 2024
News
Australia: Priority guidance on amendments to thin capitalization rules
The ATO released a list of priority public advice and guidance topics arising from amendments to the thin capitalization rules.
May 15, 2024
Transfer Pricing and BEPS
No results found.
News
Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One nearing completion
The OECD released a statement by the co-chairs of the Inclusive Framework on Base Erosion and Profit Shifting.
May 30, 2024
News
Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury on the primary legislation
May 23, 2024
News
KPMG report: Employee data reporting for public country-by-country reporting
Discusses how navigating complexities of public CbC reporting requires an understanding of nuances of employee data reporting
May 2, 2024
United States
Asia Pacific
News
Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury on the primary legislation
May 23, 2024
News
Australia: Tax promoter bill passes Parliament
The bill proposes to improve the ability of the ATO to target promoters of tax exploitation schemes.
May 17, 2024
News
Australia: Priority guidance on amendments to thin capitalization rules
The ATO released a list of priority public advice and guidance topics arising from amendments to the thin capitalization rules.
May 15, 2024
April 2024
News
OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples
The OECD released a consolidated commentary to Pillar Two global anti-base erosion (GloBE) rules.
April 30, 2024
News
OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
News
Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury
April 19, 2024
News
KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
April 2, 2024
News
Treasury Secretary Yellen testifies at House Ways and Means Committee hearing on administration’s FY 2025 tax proposals
Written testimony from Secretary of the Treasury
April 30, 2024
News
Final regulations: Definition of domestically controlled qualified investment entity under section 897
When foreign persons are considered to directly or indirectly hold stock in a QIE
April 24, 2024
News
IRS Independent Office of Appeals announces formation of alternative dispute resolution program management office
Collaboration with IRS business operating divisions to help taxpayers resolve tax disputes
April 24, 2024
News
KPMG report: Partnership audit rules and specific IRS forms
Partnership audit rules enacted by the BBA have altered how partners report and pay tax on adjustments
April 15, 2024
News
United States: Updated instructions highlight potential need to request CAMT information from partnerships
Many sovereign wealth funds and large public pensions plans have begun the complex task of analyzing their investment structures
April 9, 2024
News
KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
April 2, 2024
News
Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance
Tax Tribunal decision
April 25, 2024
News
Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury
April 19, 2024
News
Australia: Performance audit report on management of transfer pricing for related-party debt
The audit was done to provide assurance to the Parliament that the ATO “effectively manages transfer pricing for related party debt.”
April 18, 2024
News
India - Mauritius tax treaty update
Protocol to amend double taxation avoidance agreement (DTAA) that includes a principal purpose test rule
April 17, 2024
Transfer Pricing and BEPS
News
OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples
The OECD released a consolidated commentary to Pillar Two global anti-base erosion (GloBE) rules.
April 30, 2024
News
OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy
Updates on international tax initiative to assist developing countries in boosting tax revenues and better mobilizing domestic resources
April 29, 2024
News
Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury
April 19, 2024
News
KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
April 2, 2024
United States
News
Treasury Secretary Yellen testifies at House Ways and Means Committee hearing on administration’s FY 2025 tax proposals
Written testimony from Secretary of the Treasury
April 30, 2024
News
Final regulations: Definition of domestically controlled qualified investment entity under section 897
When foreign persons are considered to directly or indirectly hold stock in a QIE
April 24, 2024
News
IRS Independent Office of Appeals announces formation of alternative dispute resolution program management office
Collaboration with IRS business operating divisions to help taxpayers resolve tax disputes
April 24, 2024
News
KPMG report: Partnership audit rules and specific IRS forms
Partnership audit rules enacted by the BBA have altered how partners report and pay tax on adjustments
April 15, 2024
News
United States: Updated instructions highlight potential need to request CAMT information from partnerships
Many sovereign wealth funds and large public pensions plans have begun the complex task of analyzing their investment structures
April 9, 2024
News
KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations
Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences
April 2, 2024
Asia Pacific
News
Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance
Tax Tribunal decision
April 25, 2024
News
Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules
KPMG tax professionals provided a submission to Treasury
April 19, 2024
News
Australia: Performance audit report on management of transfer pricing for related-party debt
The audit was done to provide assurance to the Parliament that the ATO “effectively manages transfer pricing for related party debt.”
April 18, 2024
News
India - Mauritius tax treaty update
Protocol to amend double taxation avoidance agreement (DTAA) that includes a principal purpose test rule
April 17, 2024
March 2024
No results found.
News
Australia: Consultation on draft legislation, regulations to streamline administration of fuel, alcohol excise
Consultation for these draft materials closes on 5 April 2024.
March 25, 2024
News
KPMG report: Amount B compliance challenges
Compliance challenges associated with the Amount B consensus document
March 19, 2024
News
KPMG report: Implications of ICAP statistics
ICAP statistics and implications for businesses looking to obtain tax certainty
March 19, 2024
News
Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting
In response to the government’s request for comments, KPMG tax professionals provided a submission to Treasury.
March 6, 2024
News
United States: IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals
Qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) FAQs website
March 22, 2024
News
KPMG report: Tax and trade considerations for U.S. inbound investment
Insights on U.S. real property investment and existing U.S. operations acquisition
March 18, 2024
News
KPMG report: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget
Proposals will likely serve as the basis of the Biden Campaign tax plan
March 14, 2024
News
KPMG report: New beneficial ownership information reporting requirements
Origin of the new BOI reporting rule and new due diligence requirements
March 14, 2024
News
Treasury releases “Green Book” explanation of tax proposals in FY 2025 budget
“General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals”
March 11, 2024
News
Australia: Taxpayer entitled to interest deductions with respect to foreign related-party financing for third-party acquisition
Federal Court decision
March 25, 2024
News
Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules
Consultation on primary legislation closes 16 April 2024, and consultation on subordinate legislation closes 16 May 2024.
March 22, 2024
News
Australia: Guidance on applying for variations from foreign resident capital gains withholding
12.5% FRCGW applies to all property sales of AU$750,000 or more unless there is an approved variation
March 12, 2024
News
Malaysia: Recent guidance on capital gains tax
Guidance on application of the capital gains tax in Malaysia
March 6, 2024
News
Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting
In response to the government’s request for comments, KPMG tax professionals provided a submission to Treasury.
March 6, 2024
News
India: Deductions for payments to nonresidents upheld; discount by telecom company to distributor not a commission
Reports about recent court decisions
March 5, 2024
News
Germany: Tax reform bill enacted, other tax developments
Recent tax developments in Germany
March 26, 2024
News
Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules
Legislative and revenue practice changes that may have an impact for funds and the asset management industry
March 25, 2024
Transfer Pricing and BEPS
No results found.
News
Australia: Consultation on draft legislation, regulations to streamline administration of fuel, alcohol excise
Consultation for these draft materials closes on 5 April 2024.
March 25, 2024
News
KPMG report: Amount B compliance challenges
Compliance challenges associated with the Amount B consensus document
March 19, 2024
News
KPMG report: Implications of ICAP statistics
ICAP statistics and implications for businesses looking to obtain tax certainty
March 19, 2024
News
Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting
In response to the government’s request for comments, KPMG tax professionals provided a submission to Treasury.
March 6, 2024
United States
News
United States: IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals
Qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) FAQs website
March 22, 2024
News
KPMG report: Tax and trade considerations for U.S. inbound investment
Insights on U.S. real property investment and existing U.S. operations acquisition
March 18, 2024
News
KPMG report: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget
Proposals will likely serve as the basis of the Biden Campaign tax plan
March 14, 2024
News
KPMG report: New beneficial ownership information reporting requirements
Origin of the new BOI reporting rule and new due diligence requirements
March 14, 2024
News
Treasury releases “Green Book” explanation of tax proposals in FY 2025 budget
“General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals”
March 11, 2024
Asia Pacific
News
Australia: Taxpayer entitled to interest deductions with respect to foreign related-party financing for third-party acquisition
Federal Court decision
March 25, 2024
News
Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules
Consultation on primary legislation closes 16 April 2024, and consultation on subordinate legislation closes 16 May 2024.
March 22, 2024
News
Australia: Guidance on applying for variations from foreign resident capital gains withholding
12.5% FRCGW applies to all property sales of AU$750,000 or more unless there is an approved variation
March 12, 2024
News
Malaysia: Recent guidance on capital gains tax
Guidance on application of the capital gains tax in Malaysia
March 6, 2024
News
Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting
In response to the government’s request for comments, KPMG tax professionals provided a submission to Treasury.
March 6, 2024
News
India: Deductions for payments to nonresidents upheld; discount by telecom company to distributor not a commission
Reports about recent court decisions
March 5, 2024
Europe
News
Germany: Tax reform bill enacted, other tax developments
Recent tax developments in Germany
March 26, 2024
News
Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules
Legislative and revenue practice changes that may have an impact for funds and the asset management industry
March 25, 2024
Tax Services
February 2024
No results found.
News
OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
Latest developments include BEPS initiatives, tax transparency efforts and other G20 tax deliverables
February 29, 2024
News
KPMG report: Overview and initial observations on Pillar One – Amount B
Overview of the OECD report on Amount B and initial observations on how multinationals can respond
February 21, 2024
News
KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
February 21, 2024
News
OECD: Report on Amount B under Pillar One
Simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities
February 19, 2024
News
KPMG report: Legal advice memorandum shows IRS approach to intercompany debt pricing
A report that discusses recent IRS legal advice memorandum and issue of implicit support
February 8, 2024
News
KPMG article: Challenges and opportunities faced by CAMT “scope bubble corporations”
It remains uncertain whether certain corporations close to the $1 billion average annual AFSI threshold are within the scope of CAMT.
February 26, 2024
News
Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)
IRS released final Form 4626 and accompanying instructions for the new corporate alternative minimum tax
February 16, 2024
News
KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups
Examples of how U.S. entities’ transfer pricing true-ups may affect GloBE ETR in the United States or a foreign jurisdiction
February 8, 2024
News
Australia: Individual income tax and medicare levy bills pass both Houses of Parliament
The bills await Royal Assent
February 28, 2024
News
Korea: Software fees paid to Irish affiliate treated as royalties paid to U.S. parent (Tax Tribunal decision)
A Tax Tribunal decision concerning software fees paid to Irish affiliate treated as royalties paid to U.S. parent.
February 27, 2024
News
Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules
Proposals implementing Pillar Two global minimum tax rules for financial years starting 1 January 2025
February 20, 2024
News
Australia: Senate Committee report on interest limitation / thin capitalisation rules bill
Senate Committee recommended amendments to legislation containing new interest limitation /thin capitalisation rules be agreed to and passed
February 6, 2024
News
India: Tax measures in interim budget 2024
The Finance Minister presented the Interim Union Budget 2024.
February 2, 2024
News
Germany: Compromise tax reform bill adopted by mediation committee of Parliament, other tax developments
The mediation committee of Parliament adopted a compromise tax reform bill.
February 29, 2024
News
Switzerland: Tax aspects of limited qualified investor fund for real estate investments
A new investment vehicle will be available to qualified investors beginning 1 March 2024.
February 22, 2024
News
EU: Updates to list of non-cooperative jurisdictions
EU blacklist now consists of 12 jurisdictions
February 21, 2024
News
Netherlands: Consultation on new framework for determining characterization for tax purposes of foreign legal forms
Consultation closes on 18 March 2024
February 12, 2024
Transfer Pricing and BEP
No results found.
News
OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms
Latest developments include BEPS initiatives, tax transparency efforts and other G20 tax deliverables
February 29, 2024
News
KPMG report: Overview and initial observations on Pillar One – Amount B
Overview of the OECD report on Amount B and initial observations on how multinationals can respond
February 21, 2024
News
KPMG report: HMRC guidance on OECD’s control of risk framework
Implications that HMRC guidance has for transfer pricing policies
February 21, 2024
News
OECD: Report on Amount B under Pillar One
Simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities
February 19, 2024
News
KPMG report: Legal advice memorandum shows IRS approach to intercompany debt pricing
A report that discusses recent IRS legal advice memorandum and issue of implicit support
February 8, 2024
United States
News
KPMG article: Challenges and opportunities faced by CAMT “scope bubble corporations”
It remains uncertain whether certain corporations close to the $1 billion average annual AFSI threshold are within the scope of CAMT.
February 26, 2024
News
Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)
IRS released final Form 4626 and accompanying instructions for the new corporate alternative minimum tax
February 16, 2024
News
KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups
Examples of how U.S. entities’ transfer pricing true-ups may affect GloBE ETR in the United States or a foreign jurisdiction
February 8, 2024
Asia Pacific
News
Australia: Individual income tax and medicare levy bills pass both Houses of Parliament
The bills await Royal Assent
February 28, 2024
News
Korea: Software fees paid to Irish affiliate treated as royalties paid to U.S. parent (Tax Tribunal decision)
A Tax Tribunal decision concerning software fees paid to Irish affiliate treated as royalties paid to U.S. parent.
February 27, 2024
News
Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules
Proposals implementing Pillar Two global minimum tax rules for financial years starting 1 January 2025
February 20, 2024
News
Australia: Senate Committee report on interest limitation / thin capitalisation rules bill
Senate Committee recommended amendments to legislation containing new interest limitation /thin capitalisation rules be agreed to and passed
February 6, 2024
News
India: Tax measures in interim budget 2024
The Finance Minister presented the Interim Union Budget 2024.
February 2, 2024
Europe
News
Germany: Compromise tax reform bill adopted by mediation committee of Parliament, other tax developments
The mediation committee of Parliament adopted a compromise tax reform bill.
February 29, 2024
News
Switzerland: Tax aspects of limited qualified investor fund for real estate investments
A new investment vehicle will be available to qualified investors beginning 1 March 2024.
February 22, 2024
News
EU: Updates to list of non-cooperative jurisdictions
EU blacklist now consists of 12 jurisdictions
February 21, 2024
News
Netherlands: Consultation on new framework for determining characterization for tax purposes of foreign legal forms
Consultation closes on 18 March 2024
February 12, 2024
January 2024
News
Australia: Guide on details of R&D tax transparency reports
What and when R&D information will be published, common errors, and how to make amendments
January 31, 2024
News
Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion
Hybrid mismatch rules largely follow the OECD hybrid mismatch and branch mismatch rules from Action 2
January 29, 2024
News
Netherlands: Only beneficial owner of dividend entitled to credit dividend withholding tax (Supreme Court decision)
A Dutch Supreme Court held that only beneficial owner of dividends is entitled to credit dividend withholding tax with respect to such dividends
January 24, 2024
News
Italy: Procedure for obtaining hybrid mismatch penalty protection
Rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence
January 19, 2024
News
KPMG report: New year, changing information reporting and withholding (IRW) requirements
How organizations can prepare for electronic filing requirement threshold changes
January 31, 2024
News
KPMG report: Resurgence of transfer pricing penalties
IRS shift toward increased penalty assertion; procedural considerations for taxpayers
January 23, 2024
News
KPMG report: Key takeaways from recent CAMT releases
Summary of notable provisions and KPMG observations
January 17, 2024
News
IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships
The IRS announced continued progress to expand enforcement efforts related to high-income individuals, large corporations, and complex partnerships.
January 12, 2024
News
Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)
Legal advice memorandum from the Office of Chief Counsel
January 2, 2024
Asia Pacific
News
Australia: Guide on details of R&D tax transparency reports
What and when R&D information will be published, common errors, and how to make amendments
January 31, 2024
News
Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion
Hybrid mismatch rules largely follow the OECD hybrid mismatch and branch mismatch rules from Action 2
January 29, 2024
Europe
News
Netherlands: Only beneficial owner of dividend entitled to credit dividend withholding tax (Supreme Court decision)
A Dutch Supreme Court held that only beneficial owner of dividends is entitled to credit dividend withholding tax with respect to such dividends
January 24, 2024
News
Italy: Procedure for obtaining hybrid mismatch penalty protection
Rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence
January 19, 2024
United States
News
KPMG report: New year, changing information reporting and withholding (IRW) requirements
How organizations can prepare for electronic filing requirement threshold changes
January 31, 2024
News
KPMG report: Resurgence of transfer pricing penalties
IRS shift toward increased penalty assertion; procedural considerations for taxpayers
January 23, 2024
News
KPMG report: Key takeaways from recent CAMT releases
Summary of notable provisions and KPMG observations
January 17, 2024
News
IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships
The IRS announced continued progress to expand enforcement efforts related to high-income individuals, large corporations, and complex partnerships.
January 12, 2024
News
Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)
Legal advice memorandum from the Office of Chief Counsel
January 2, 2024
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