This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 October and 31 October 2025.
International Tax Europe and Africa October 2025
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For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.
To contact the International Tax Team email internationaltax@kpmg.com.
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Angola
Angola | |||
Tax legislation approved and regulatory update | Tax compliance | 28 October 2025 | Legislation introducing mandatory electronic invoicing (e-invoicing) effective October 1, 2025. Read more |
Tax legislation approved and regulatory update | Indirect tax | 28 October 2025 | Automatic submission of periodic value added tax (VAT) return. Read more |
Tax legislation approved and regulatory update | Indirect tax | 02 October 2025 | Mandatory electronic invoicing (e-invoicing) implementation postponed. Read more |
Austria
Austria | |||
Proposed legislation | Income tax | 22 October 2025 | Proposed changes to real estate transfer tax on share transfers. Read more |
Belgium
Belgium | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 24 October 2025 | Guidance on implementation of Pillar Two rules. Read more |
Administrative and case law | Transfer Pricing | 23 October 2025 | Interest rate on intra-group loan held non-arm’s length under comparable uncontrolled price method (court decision). Read more |
Proposed legislation | BEPS Pillar 2 | 10 October 2025 | Draft legislation amending Pillar Two rules. Read more |
Tax legislation approved and regulatory update | Indirect tax | 03 October 2025 | Indefinite postponement of modernization of Value Added Tax (VAT) rules. Read more |
Cyprus
Czech Republic | |||
Proposed legislation | Various tax topics | 31 October 2025 | Tax reform proposal submitted to Parliament. Read more |
Administrative and case law | Income tax | 10 October 2025 | Submission of withholding tax declarations and payments with respect to certain transactions with nonresidents must be made via Tax For All (TFA) system. Read more |
Czech Republic
Czech Republic | |||
Administrative and case law | Income tax | 14 October 2025 | Summaries of recent Supreme Administrative Court (SAC) decisions. Read more |
Denmark
Denmark | |||
Tax legislation approved and regulatory update | Tax compliance | 17 October 2025 | Reporting obligations for cryptoasset service providers (DAC8). Read more |
Proposed legislation | Income tax | 13 October 2025 | Proposed expansion of preferential tax scheme for small and medium-sized enterprises (SMEs) offering share-based incentives to employees. Read more |
Estonia
Estonia | |||
Administrative and case law | Indirect tax | 30 October 2025 | “Construction services” in Finland held intra-community supply of goods subject to Value Added Tax (VAT) (Circuit Court decision). Read more |
European Union
European Union | |||
Tax legislation approved and regulatory update | Tax Compliance | 31 October 2025 | European Commission (EC) publishes 2026 version of Combined Nomenclature (CN). Read more |
Tax legislation approved and regulatory update | Various tax topics | 29 October 2025 | Upgraded trade agreement between the European Union (EU) and Ukraine enters into force. Read more |
Other | Various tax topics | 23 October 2025 | European Union (EU) adopts 19th package of sanctions against Russia. Read more |
Proposed legislation | Various tax topics | 22 October 2025 | Updates on tax initiatives in European Commission (EC) 2026 Work Programme. Read more |
Tax legislation approved and regulatory update | Indirect tax | 20 October 2025 | Amending protocol with Switzerland to strengthen tax cooperation. Read more |
Administrative and case law | BEPS Pillar 1 | 17 October 2025 | European Commissioner (EC) answers question on digital taxation in Europe & resolution on role of simple tax rules and tax fragmentation in European Union (EU) competitiveness. Read more |
Administrative and case law | Various tax topics | 16 October 2025 | Economic and Financial Affairs Council of the EU (ECOFIN Council) conclusions on European Commission (EC) recommendations regarding tax incentives to support Clean Industrial Deal. Read more |
Other | Indirect tax | 14 October 2025 | Report on deviations by member states from standard Value Added Tax (VAT) rates. Read more |
Tax legislation approved and regulatory update | Tax compliance | 13 October 2025 | Amending protocols to Common Reporting Standard (CRS) agreements with Andorra, Liechtenstein, Monaco, and San Marino & mandate to start negotiations with Norway. Read more |
Tax legislation approved and regulatory update | Various tax topics | 10 October 2025 | Updated list of non-cooperative tax jurisdictions. Read more |
Administrative and case law | Income tax | 09 October 2025 | Court of Justice of the European Union (CJEU) lacks jurisdiction in case regarding capital gains taxation under special levy (Slovakia). Read more |
Administrative and case law | Indirect tax | 09 October 2025 | Court of Justice of the European Union (CJEU) confirms electronic marketplaces qualify as undisclosed agents pre-2015 amendments. Read more |
Finland
Finland | |||
KPMG publications | Tax compliance | 16 October 2025 | Updated Foreign Account Tax Compliance Act (FATCA) guidance & new rules under cryptoasset reporting framework (CARF). Read more |
France
France | |||
Tax legislation approved and regulatory update | Indirect tax | 27 October 2025 | Value Added Tax (VAT) exemption lists for Guadeloupe, Martinique, and Réunion. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 1 | 27 October 2025 | No implementation of Pillar One Amount B, but acceptance of Amount B outcomes in covered jurisdictions. Read more |
Proposed legislation | Various tax topics | 21 October 2025 | Tax measures in 2026 Finance Bill include amendments to Pillar Two rules. Read more |
Administrative and case law | BEPS Pillar 2 | 17 October 2025 | New guidance on Pillar Two rules & notice on common Pillar Two reporting errors. Read more |
Germany
Germany | |||
Tax legislation approved and regulatory update | Various tax topics | 30 October 2025 | Periodic Update of the EU Blacklist (October 2025). Read more |
Administrative and case law | BEPS Pillar 2 | 30 October 2025 | Lower Tax Court of Hesse (3 K 778/21): Taxation of a Contribution Gain II May Violate Merger Directive. Read more |
Administrative and case law | Indirect tax | 30 October 2025 | Federal Tax Court (II R 26/23): Real Estate Transfer Tax in Cases Where the 95% Threshold is Exceeded Again and Application of the Correction Provision in Cases Where a Share Deal is Subsequently Cancelled. Read more |
Administrative and case law | Income tax | 30 October 2025 | Federal Tax Court (II B 23/25): Real Estate Transfer Tax in so-called Signing-Closing Cases. Read more |
Proposed legislation | BEPS Pillar 1 | 30 October 2025 | Ministerial Draft Bill for an Act to Amend the MLI Implementation Act. Read more |
Proposed legislation | Treaties | 30 October 2025 | Draft legislation to expand Multilateral Instrument (MLI) to 62 additional treaties & other tax developments. Read more |
Proposed legislation | Tax Compliance | 30 October 2025 | Government Draft Bill for Active Pension Act. Read more |
Proposed legislation | Various tax topics | 21 October 2025 | Value Added Tax (VAT) measures included in Tax Amendment Act of 2025 & other VAT developments. Read more |
Proposed legislation | Various tax topics | 15 October 2025 | Draft legislation including various amendments to tax law. Read more |
Administrative and case law | Tax compliance | 14 October 2025 | Deactivation of Electronic Situation Display (ELAN) system and transition to new Foreign Account Tax Compliance Act (FATCA) reporting systems. Read more |
Administrative and case law | Tax compliance | 10 October 2025 | New mass data interface (DIP) for Common Reporting Standard (CRS) reporting. Read more |
Greece
Greece | |||
Tax legislation approved and regulatory update | Indirect tax | 21 October 2025 | Guidance on applicability and administrative aspects of cruise tax. Read more |
Hungary
Hungary | |||
Proposed legislation | BEPS Pillar 2 | 20 October 2025 | Tax declaration Form 24GLBADO for qualifying domestic minimum top-up tax. Read more |
Proposed legislation | Various tax topics | 15 October 2025 | Consultation on autumn tax package. Read more |
Tax legislation approved and regulatory update | Indirect tax | 09 October 2025 | Guidelines on Value Added Tax (VAT) group succession issues. Read more |
Administrative and case law | Tax compliance | 01 October 2025 | Carbon border adjustment mechanism (CBAM) authorization procedure launched. Read more |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | Various tax topics | 17 October 2025 | Direct and indirect tax measures in Finance Bill 2025. Read more |
Tax legislation approved and regulatory update | Indirect tax | 08 October 2025 | Phased rollout of mandatory electronic invoicing (e-invoicing) and real-time Value Added Tax (VAT) reporting. Read more |
Tax legislation approved and regulatory update | Various tax topics | 08 October 2025 | Direct and indirect tax measures in 2026 budget. Read more |
Italy
Italy | |||
KPMG publications | Indirect tax | 27 October 2025 | Role of fixed establishment in negotiating contracts & standard Value Added Tax (VAT) rate for hearing aid repair services. Read more |
Latvia
Latvia | |||
Proposed legislation | Indirect tax | 30 October 2025 | Proposed changes to application of reduced Value Added Tax (VAT) rates for publications and food products. Read more |
Liechtenstein
Liechtenstein | |||
Tax legislation approved and regulatory update | Tax compliance | 22 October 2025 | Statement adopted on the Cryptoasset Reporting Framework (CARF), amended Common Reporting Standard (CRS), and protocol signed with European Union amending Automatic Exchange of Information agreement. Read more |
Lithuania
Lithuania | |||
Tax legislation approved and regulatory update | Income tax | 27 October 2025 | Amendments to corporate income taxation effective January 1, 2026. Read more |
Luxembourg
Luxembourg | |||
Proposed legislation | Income tax | 13 October 2025 | Amendments to bill on reforming property tax. Read more |
Moldova
Moldova | |||
Tax legislation approved and regulatory update | Income tax | 22 October 2025 | Guidance on requirements to apply small and medium-sized enterprise (SME) tax regime. Read more |
Tax legislation approved and regulatory update | Income tax | 22 October 2025 | Implementation of taxation of immovable property based on market value postponed. Read more |
Administrative and case law | Income tax | 09 October 2025 | Guidance on deductibility of expenses for optional insurance, Value Added Tax (VAT) exemption for construction and installation services for photovoltaic parks. Read more |
Monaco
Monaco | |||
Tax legislation approved and regulatory update | Tax compliance | 23 October 2025 | Protocol with European Union (EU) amending automatic exchange of financial account information (AEOI) agreement signed. Read more |
Netherlands
Netherlands | |||
Other | BEPS Pillar 2 | 28 October 2025 | KPMG report: “Amsterdam Dialogue on Global Minimum Tax Compliance” stakeholder meeting, October 2025. Read more |
Tax legislation approved and regulatory update | Income tax | 22 October 2025 | Updated “Question & Answer (Q&A) decree” on innovation box. Read more |
Administrative and case law | Income tax | 22 October 2025 | Dividend withholding tax exemption denied to structures aimed at tax avoidance (Supreme Court decision). Read more |
Tax legislation approved and regulatory update | Income tax | 22 October 2025 | Guidance on scope of Anti-Tax Avoidance Directive (ATAD) interest deduction limitation rules. Read more |
Tax legislation approved and regulatory update | Indirect tax | 16 October 2025 | Guidance on scope of Value Added Tax (VAT) exemption for intermediation activities in shares and other securities transactions. Read more |
KPMG publications | Various tax topics | 06 October 2025 | KPMG report: Global tax and legal environmental, social, and governance (ESG)-related developments. Read more |
KPMG publications | Various tax topics | 02 October 2025 | KPMG report: Shipping and offshore tax update (September 2025). Read more |
Administrative and case law | Income tax | 02 October 2025 | Interest rate on corporate income tax due found contrary to principle of proportionality (Supreme Court Advocate General opinion). Read more |
Nigeria
Nigeria | |||
Administrative and case law | Indirect tax | 27 October 2025 | Rideshare platform operators may be designated as Value Added Tax (VAT) collection agents (High Court decision). Read more |
North Macedonia
North Macedonia | |||
Tax legislation approved and regulatory update | Indirect tax | 06 October 2025 | North Macedonia: Electronic invoicing (e-invoicing) to launch third quarter of 2026. Read more |
Norway
Norway | |||
Proposed legislation | Various tax topics | 16 October 2025 | Direct and indirect tax measures in 2026 budget proposal. Read more |
OECD
OECD | |||
Other | Transfer Pricing | 31 October 2025 | “Tax Certainty Day” highlights Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) statistics. Read more |
Tax legislation approved and regulatory update | Transfer Pricing | 23 October 2025 | Third batch of updated transfer pricing country profiles. Read more |
Tax legislation approved and regulatory update | Transfer Pricing | 21 October 2025 | Brazil signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Read more |
Other | Various tax topics | 16 October 2025 | Report to G20 Finance Ministers and Central Bank Governors, recent developments in international tax cooperation. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 1 | 01 October 2025 | Argentina submits instrument of ratification for Base Erosion and Profit Shifting (BEPS) Convention. Read more |
Poland
Poland | |||
Administrative and case law | Various tax topics | 29 October 2025 | Reduced excise duty for hybrid vehicles, hidden profits of Chief executive officer, Value Added Tax (VAT) treatment of granting loan & government Research & Development funds not subject to VAT. Read more |
Tax legislation approved and regulatory update | Indirect tax | 29 October 2025 | New rules concerning carbon border adjustment mechanism (CBAM). Read more |
KPMG publications | Various tax topics | 21 October 2025 | Amendments to taxation of banks, corporate income tax rules, excise duty on alcoholic beverages, fees on sugar/caffeine content in beverages. Read more |
Administrative and case law | Indirect tax | 14 October 2025 | Summaries of recent Supreme Administrative Court decisions. Read more |
KPMG publications | Various tax topics | 14 October 2025 | Amendments to sugar and gaming tax, rules applying preferential depreciation, tax procedures. Read more |
Proposed legislation | Income tax | 08 October 2025 | Bill increasing corporate income tax rate on banks passed by Council of Ministers. Read more |
Administrative and case law | Indirect tax | 08 October 2025 | Ordering party paying subcontractors must use split payment mechanism under Value Added Tax (VAT) law (Supreme Administrative Court decision). Read more |
Tax legislation approved and regulatory update | Indirect tax | 08 October 2025 | Extension of 50% Value Added Tax (VAT) deduction limit approved by European Union (EU) Council. Read more |
Tax legislation approved and regulatory update | Income tax | 02 October 2025 | Leased passenger cars subject to new cap on tax-deductible costs, regardless of when contract concluded. Read more |
Tax legislation approved and regulatory update | Various tax topics | 02 October 2025 | Proposed amendments to direct and indirect tax laws. Read more |
Administrative and case law | Indirect tax | 02 October 2025 | Company formed by local government not Value Added Tax (VAT) payer & excise duty exemption depends on rate applicable when energy produced. Read more |
Romania
Romania | |||
Tax legislation approved and regulatory update | Indirect tax | 14 October 2025 | New law repeals Value Added Tax (VAT) exemption for non-governmental organizations (NGOs), increases VAT and dividend tax rates, and introduces supplementary tax on banks. Read more |
Tax legislation approved and regulatory update | Transfer Pricing | 14 October 2025 | Amendments to rules for advance pricing agreements (APAs) and mutual agreement procedure. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 09 October 2025 | Form for declaration and payment of Pillar Two taxes approved. Read more |
Serbia
Serbia | |||
Tax legislation approved and regulatory update | Indirect tax | 13 October 2025 | Amendments to electronic invoicing (e-invoicing) rulebook. Read more |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 31 October 2025 | Legislation amending Pillar Two rules approved by Parliament. Read more |
Tax legislation approved and regulatory update | Transfer Pricing | 28 October 2025 | Updated guidelines on transfer pricing documentation. Read more |
Proposed legislation | Indirect tax | 01 October 2025 | Draft amendments to Value Added Tax (VAT) law submitted to Parliament. Read more |
Slovenia
Slovenia | |||
Tax legislation approved and regulatory update | Indirect tax | 31 October 2025 | Mandatory electronic invoicing (e-invoicing) for business-to-business (B2B) transactions. Read more |
South Africa
South Africa | |||
Administrative and case law | Income tax | 31 October 2025 | General anti-avoidance rules (GAAR) applied to recharacterize tax-exempt dividends as taxable service fee income (court decision). Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 29 October 2025 | South Africa: Updates to global anti-base erosion (GloBE) reporting. Read more |
Proposed legislation | Tax compliance | 14 October 2025 | Draft regulations implementing cryptoasset reporting framework (CARF) and amending Common Reporting Standards (CRS). Read more |
Spain
Spain | |||
Tax legislation approved and regulatory update | Tax compliance | 30 October 2025 | Timeline for adaptation of invoicing systems. Read more |
Tax legislation approved and regulatory update | Indirect tax | 24 October 2025 | New H1 system for electronic declaration of imports mandatory as of October 14, 2025. Read more |
Administrative and case law | Indirect tax | 16 October 2025 | Valuation of moorings for real estate transfer tax purposes requires physical inspection (Balearic Islands Tribunal decision). Read more |
Administrative and case law | Transfer Pricing | 02 October 2025 | Arm’s length remuneration in cash pooling arrangements of multinational groups (Supreme Court decision). Read more |
Sweden
Sweden | |||
Tax legislation approved and regulatory update | Indirect tax | 07 October 2025 | Updated guidance on application of Value Added Tax (VAT) to asset transfers as part of business transfers. Read more |
Tax legislation approved and regulatory update | Tax compliance | 06 October 2025 | New rules for approval and revocation of “F-tax”. Read more |
Proposed legislation | Income tax | 01 October 2025 | Proposed changes to targeted interest deduction limitation rules. Read more |
Switzerland
Switzerland | |||
Administrative and case law | BEPS Pillar 2 | 14 October 2025 | Treatment of residual tax for Pillar Two top-up tax purposes. Read more |
Tanzania
Tanzania | |||
Tax legislation approved and regulatory update | Various tax topics | 13 October 2025 | Tax measures in Finance Act 2025. Read more |
Tunisia
Tunisia | |||
Proposed legislation | Indirect tax | 28 October 2025 | Proposed 2026 Finance Bill expands mandatory electronic invoicing (e-invoicing). Read more |
Ukraine
Ukraine | |||
Tax legislation approved and regulatory update | Tax compliance | 20 October 2025 | Moratorium of tax audits for certain business entities signed by president. Read more |
United Kingdom
United Kingdom | |||
Tax legislation approved and regulatory update | Income tax | 30 October 2025 | Guidance on research and development (R&D) tax relief for small and medium-sized enterprises. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 30 October 2025 | Updated list of Pillar Two territories, qualifying top-up taxes. Read more |
Administrative and case law | Income tax | 16 October 2025 | Contract termination fee after failed merger not taxable (First-tier Tribunal (FTT) decision). Read more |
Tax legislation approved and regulatory update | Tax compliance | 16 October 2025 | Guidance allowing cryptoasset exchange traded notes (cETNs) to be held in retirement savings accounts. Read more |
Tax legislation approved and regulatory update | Tax compliance | 16 October 2025 | Updated International Exchange of Information manual (IEIM). Read more |
Tax legislation approved and regulatory update | Tax compliance | 02 October 2025 | HM Revenue & Customs (HMRC) guidance on new reserved investor fund (RIF). Read more |
