International Tax Asia Pacific December 2025
This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Asia Pacific Regions between 1 December and 31 December 2025.
For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.
To contact the International Tax Team email internationaltax@kpmg.com.
To register for the International Tax webcasts, click here.
Armenia
Armenia | |||
Tax legislation approved and regulatory update | Treaties | 19 December 2025 | Income tax treaty with Japan enters into force. Read more. |
Australia
Australia | |||
Proposed legislation | Transfer pricing | 12 December 2025 | Proposed changes to transfer pricing guidance for inbound distributors. Read more. |
Administrative and case law | Income tax | 08 December 2025 | Pre-capital gains tax status can be retained when shares are held through discretionary trust (Administrative Review Tribunal decision). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 08 December 2025 | Australian Taxation Office (ATO) administrative approach to public country-by-country (CbC) reporting exemptions. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 05 December 2025 | Beneficial ownership, instant asset write-off bill receives Royal Assent. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 December 2025 | Sample combined Pillar Two return forms. Read more. |
Tax legislation approved and regulatory update | Income tax | 01 December 2025 | Beneficial ownership, instant asset write-off bill passes parliament. Read more. |
Bahrain
Bahrain | |||
Tax legislation approved and regulatory update | Various tax topics | 29 December 2025 | Updated Value Added Tax (VAT) deregistration manual and domestic minimum top-up tax frequently asked questions. Read more. |
China
China | |||
Tax legislation approved and regulatory update | Transfer pricing | 31 December 2025 | Annual advance pricing agreement (APA) report. Read more. |
Cyprus
Cyprus | |||
Tax legislation approved and regulatory update | Tax compliance | 12 December 2025 | Deadline extended to submit employers’ income tax withholding declaration for 2024. Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 10 December 2025 | Extension of zero Value Added Tax (VAT) rate on certain goods, reduced VAT rate for educational buildings. Read more. |
Hong Kong (SAR), China
Hong Kong (SAR), China | |||
Tax legislation approved and regulatory update | Treaties | 30 December 2025 | Hong Kong and Norway: Income tax treaty signed. Read more. |
| Proposed legislation | Various tax topics | 22 December 2025 | Public consultation on implementation of cryptoasset reporting framework (CARF) and common reporting standard (CRS 2.0). Read more. |
| Administrative and case lawq | Income tax | 01 December 2025 | Management fees paid to British Virgin Islands (BVI) affiliate not deductible (Court of Appeal decision). Read more. |
India
India | |||
Administrative and case law | Treaties | 29 December 2025 | Income from delivery order charges not subject to tax in India under UK treaty (tribunal decision). Read more. |
KPMG publication | Various tax topics | 17 December 2025 | Head office expenses and input tax credit provisions (court decisions). Read more. |
| Administrative and case law | Treaties | 12 December 2025 | Dividend distribution tax (DDT) cannot exceed tax treaty rate (High Court decision). Read more. |
| Administrative and case law | Transfer pricing | 11 December 2025 | “At-cost” transfer pricing model upheld for provision of technical services in oil and gas operations (tribunal decision). Read more. |
| Administrative and case law | Treaties | 09 December 2025 | Physical presence required for service permanent establishment (PE) under India-Singapore treaty (court decision). Read more. |
| Tax legislation approved and regulatory update | Treaties | 03 December 2025 | Income tax treaty with Qatar enters into force. Read more. |
| Administrative and case law | Treaties | 01 December 2025 | Taxpayer allowed foreign tax credits (FTCs) on income not taxable under Japan treaty (tribunal decision). Read more. |
Israel
Israel | |||
Tax legislation approved and regulatory update | Indirect tax | 12 December 2025 | Expansion of mandatory e-invoicing model. Read more. |
Kazakhstan
Kazakhstan | |||
Tax legislation approved and regulatory update | Income tax | 04 December 2025 | Rules for determining taxable income from banking activities. Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 04 December 2025 | New controlled foreign corporation (CFC) forms, new whitelist of countries not considered to have preferential tax regimes. Read more. |
Kuwait
Kuwait | |||
Tax legislation approved and regulatory update | Treaties | 17 December 2025 | Income tax treaty with Qatar ratified. Read more. |
Malaysia
Malaysia | |||
Tax legislation approved and regulatory update | Tax compliance | 18 December 2025 | Compliance review framework for e-invoicing. Read more. |
| KPMG publication | Various tax topics | 12 December 2025 | Tax developments summary (December 2025). Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 08 December 2025 | Stamp assessment and payment system replaced by e-Duti Setem starting January 1, 2026. Read more. |
Oman
Oman | |||
Proposed legislation | Indirect tax | 01 December 2025 | Draft data dictionary for electronic invoicing (e-invoicing). Read more. |
Philippines
Philippines | |||
Proposed legislation | Income tax | 02 December 2025 | Simplified tax framework for metallic mining. Read more. |
Sri Lanka
Sri Lanka | |||
Tax legislation approved and regulatory update | Indirect tax | 31 December 2025 | Proposed changes to tax holidays, exemptions, and concessions for strategic investments. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 15 December 2025 | Postponed implementation of new Value Added Tax (VAT) invoice format. Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 05 December 2025 | Tax exemptions and deferments due to Cyclone Ditwa. Read more. |
| Proposed legislation | Income tax | 01 December 2025 | Proposed amendments to tax incentives and exemptions (Colombo Port City). Read more. |
Taiwan
Taiwan | |||
Tax legislation approved and regulatory update | Income tax | 02 December 2025 | Guidance on foreign currency gains and losses, earnings declarations. Read more. |
Turkey
Turkey | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 17 December 2025 | Extension of qualified domestic minimum top-up tax (QDMTT) return filing deadline. Read more. |
| Tax legislation approved and regulatory update | Income tax | 16 December 2025 | Limited scope of simple method under individual income tax. Read more. |
| Proposed legislation | Various tax topics | 16 December 2025 | Tax policy reforms in medium-term program (MTP) for 2026–2028. Read more. |
United Arab Emirates
United Arab Emirates | |||
Tax legislation approved and regulatory update | Tax compliance | 23 December 2025 | Guidance on tax compliance obligations for qualifying investment funds (QIFs) and their investors. Read more. |
| Tax legislation approved and regulatory update | Income tax | 23 December 2025 | Amendments to corporate tax law relating to tax credits and incentives. Read more. |
| Tax legislation approved and regulatory update | Income tax | 18 December 2025 | Guidance on corporate tax treatment of family wealth management structures. Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 18 December 2025 | Amendments to excise tax law. Read more. |
Uzbekistan
Uzbekistan | |||
Tax legislation approved and regulatory update | Income tax | 16 December 2025 | Tax incentives for legal entities. Read more. |
Vietnam
Vietnam | |||
Tax legislation approved and regulatory update | Income tax | 18 December 2025 | Guidance on new corporate income tax (CIT) law. Read more. |
