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 December and 31 December 2025.
International Tax Europe and Africa 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.
Belgium
Belgium | |||
Proposed legislation | Various tax topics | 17 December 2025 | Updated draft law on new capital gains tax on financial assets. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 15 December 2025 | Law containing miscellaneous provisions approved by Parliament. Read more. |
Proposed legislation | Indirect tax | 05 December 2025 | Draft law confirms electronic invoicing (e-invoicing) grace period and clarifies the scope of mandate for non-residents. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 03 December 2025 | Three-month tolerance period for electronic invoicing (e-invoicing) mandate effective January 1, 2026. Read more. |
Bosnia and Herzegovina
Bosnia and Herzegovina | |||
Tax legislation approved and regulatory update | Income tax | 08 December 2025 | Updated withholding tax obligations and forms. Read more. |
Cameroon
Cameroon | |||
Tax legislation approved and regulatory update | Income tax | 08 December 2025 | Significant economic presence standard introduced from 2026. Read more. |
Czech Republic
Czech Republic | |||
Tax legislation approved and regulatory update | Income tax | 09 December 2025 | Changes in research and development (R&D) allowances effective January 1, 2026. Read more. |
Administrative and case law | Income tax | 09 December 2025 | Documentation requirements for tax-deductible depreciation of real estate improvements (Supreme Administrative Court (SAC) decision). Read more. |
Administrative and case law | Income tax | 01 December 2025 | Taxpayer not entitled to reduce tax base because change in accounting method not proven (Supreme Administrative Court decision). Read more. |
Denmark
Denmark | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 December 2025 | Expanded scope of country-by-country (CbC) reporting under DAC9, amendments to Pillar Two rules. Read more. |
Proposed legislation | Indirect tax | 02 December 2025 | Tax incentive proposals in 2026 Finance Bill. Read more. |
Estonia
Estonia | |||
Proposed legislation | Various tax topics | 01 December 2025 | Draft amendments to motor vehicle tax adopted by Parliament, other draft income and gambling tax amendments. Read more. |
European Union
European Union | |||
Administrative and case law | BEPS Pillar 2 | 17 December 2025 | Infringement procedures closed regarding Pillar Two minimum tax transposition. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 17 December 2025 | The Economic and Financial Affairs Council (ECOFIN) approves two reports on tax-related initiatives and 2025 Code of Conduct Group conclusion. Read more. |
Tax legislation approved and regulatory update | Trade & customs | 15 December 2025 | Small consignments entering European Union (EU) subject to fixed customs duty beginning July 1, 2026. Read more. |
Administrative and case law | Indirect tax | 08 December 2025 | Transfer pricing implications of The Court of Justice of the European Union (CJEU) judgment on application of Value Added Tax (VAT) to cross-border intra-group services. Read more. |
Administrative and case law | Indirect tax | 04 December 2025 | Triangulation simplification applies beyond three parties in European Union (EU) Value Added Tax (VAT) supply chains. Read more. |
Tax legislation approved and regulatory update | Trade & customs | 02 December 2025 | European Union (EU) revises Generalised Scheme of Preferences (GSP). Read more. |
Proposed legislation | Income tax | 02 December 2025 | Resolution on the Framework for Income Taxation proposal (‘BEFIT Proposal’) adopted. Read more. |
Administrative and case law | Indirect tax | 02 December 2025 | European Commission publishes report on the evaluation of the DAC. Read more. |
Administrative and case law | Various tax topics | 02 December 2025 | Court of Justice of the European Union (CJEU) rejects appeal from General Court decision that Madeira Free Zone scheme not implemented in line with approved conditions (Portugal). Read more. |
Administrative and case law | Income tax | 02 December 2025 | Court of Justice of the European Union (CJEU) judgment on compatibility with European Union law of evidentiary requirements for nonresident pension funds seeking withholding tax exemption (Portugal). Read more. |
Finland
Finland | |||
Proposed legislation | Various tax topics | 09 December 2025 | Proposed implementation of DAC8, cryptoasset reporting framework (CARF), and common reporting standard (CRS) 2.0. Read more |
France
France | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 17 December 2025 | Additional Pillar Two guidance. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 16 December 2025 | Mandatory point of sale (POS) software certification deadline postponed until September 1, 2026. Read more. |
| Tax legislation approved and regulatory update | Treaties | 11 December 2025 | Senate approves tax treaty with Finland, protocol to tax treaty Sweden. Read more. |
Georgia
Georgia | |||
Proposed legislation | Treaties | 04 December 2025 | Protocols to income and capital tax treaties with San Marino and Luxembourg ratified. Read more. |
Germany
Germany | |||
Administrative and case law | Treaties | 15 December 2025 | Withholding tax on dividends paid by German hybrid entities. Read more. |
Administrative and case law | Indirect tax | 10 December 2025 | Input tax deduction in absence of tax statement, other Value Added Tax (VAT) developments. Read more. |
| Administrative and case law | Tax compliance | 09 December 2025 | Obligation to disclose emails in tax audits (court decision). Read more. |
| Tax legislation approved and regulatory update | Treaties | 01 December 2025 | Pending protocols to income tax treaties with the Netherlands and Switzerland approved by lower house of Parliament. Read more. |
| Proposed legislation | Various tax topics | 01 December 2025 | Draft legislation extending vehicle tax exemption for electronic vehicles. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 01 December 2025 | Guidance on transition from ELAN to POSt for FATCA reporting. Read more. |
Greece
Greece | |||
Tax legislation approved and regulatory update | Income tax | 11 December 2025 | New super-deduction tax incentives for defense sectors and manufacturing of vehicles, aircraft. Read more. |
Administrative and case law | Income tax | 02 December 2025 | Ministry of Finance clarifies tax treatment of profit distributions relating to previously exempt periods. Read more. |
| Proposed legislation | Income tax | 02 December 2025 | Super-deduction regime to support investment in defense-related and allied manufacturing units. Read more. |
Guernsey
Guernsey | |||
Administrative and case law | BEPS Pillar 2 | 02 December 2025 | Pillar Two registration portal launched. Read more. |
Hungary
Hungary | |||
Tax legislation approved and regulatory update | Treaties | 16 December 2025 | President signs laws ratifying multilateral agreements concerning international tax transparency. Read more. |
Proposed legislation | Transfer pricing | 04 December 2025 | Proposed changes to transfer pricing documentation and data disclosure. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 02 December 2025 | Tax amendments bills enacted (including Pillar Two and tax incentive changes). Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 01 December 2025 | Autumn tax package adopted, including changes to global minimum tax rules. Read more. |
Iceland
Iceland | |||
Tax legislation approved and regulatory update | Indirect tax | 17 December 2025 | Guidelines on Value Added Tax (VAT) obligations for cruise ship operators. Read more. |
| Proposed legislation | Income tax | 17 December 2025 | Proposed tax reform bill. Read more. |
| Proposed legislation | BEPS Pillar 2 | 17 December 2025 | Budget 2026 proposes implementation of Pillar Two global minimum tax rules. Read more. |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 December 2025 | Extension of Pillar Two registration deadline. Read more. |
Jersey
Jersey | |||
Tax legislation approved and regulatory update | Various tax topics | 18 December 2025 | Channel Islands: Draft regulations implementing cryptoasset reporting framework (CARF) (Jersey). Read more. |
Kenya
Kenya | |||
Administrative and case law | Income tax | 15 December 2025 | Five-year tax loss carryforward limit under Finance Act 2025. Read more. |
| Administrative and case law | Indirect tax | 15 December 2025 | Valued added tax (VAT) exemption upheld on disposal of salvage vehicles by insurers. Read more. |
| Administrative and case law | Tax compliance | 15 December 2025 | Requirements for obtaining tax compliance certificate (TCC). Read more. |
Latvia
Latvia | |||
Proposed legislation | Various tax topics | 18 December 2025 | Tax measures in 2026 budget. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 02 December 2025 | Partial implementation of reporting obligations for cryptoasset service providers Directive on Administrative Cooperation (2023/2226) (DAC8). Read more. |
Lithuania
Lithuania | |||
Tax legislation approved and regulatory update | Various tax topics | 04 December 2025 | Amendments to corporate income tax, Value Added Tax (VAT), excise taxes, and real estate tax, introduction of insurance premium tax. Read more. |
Moldova
Moldova | |||
Administrative and case law | Indirect tax | 05 December 2025 | Clarifications on Value Added Tax (VAT) on vending machines and application of accelerated depreciation. Read more. |
| Administrative and case law | Indirect tax | 05 December 2025 | Constitutional Court upholds Value Added Tax (VAT) refund regulation. Read more. |
Netherlands
Netherlands | |||
Tax legislation approved and regulatory update | Various tax topics | 22 December 2025 | Advertisement tax regime to resume July 1, 2026. Read more. |
| Administrative and case law | Transfer pricing | 22 December 2025 | Interest expense may be non-deductible when acquisitions financed with shareholder loans (Supreme Court decision). Read more. |
| Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 December 2025 | 2026 Tax Plan approved by upper house of Parliament, including Pillar Two changes and implementation of DAC9. Read more. |
| Proposed legislation | Various tax topics | 18 December 2025 | Internet consultation on changes to definition of mutual fund and introduction of an opt-out scheme. Read more. |
| Administrative and case law | Income tax | 16 December 2025 | Interest expenses non-deductible when debt acquisition abuses law (Supreme Court decision). Read more. |
| Administrative and case law | Treaties | 16 December 2025 | Treaty benefits under income tax treaty with Malta denied (Supreme Court decision). Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 16 December 2025 | Updated Value Added Tax (VAT) decree on fuel cards and negative interest. Read more. |
| Tax legislation approved and regulatory update | Income tax | 01 December 2025 | 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9. Read more. |
Nigeria
Nigeria | |||
Administrative and case law | Tax compliance | 09 December 2025 | Tax Appeal Tribunal affirms authority to grant interim and interlocutory reliefs in tax disputes. Read more. |
| Tax legislation approved and regulatory update | Income tax | 04 December 2025 | Guidance on withholding tax on interest from short-term securities, duty-free threshold for low-value imports, tax administration reform. Read more. |
OECD
OECD | |||
Tax legislation approved and regulatory update | Various tax topics | 18 December 2025 | Peer review results on base erosion and profit shifting (BEPS) Action 5. Read more. |
Administrative and case law | Transfer pricing | 04 December 2025 | KPMG article: Organisation for Economic Cooperation and Development (OECD)’s 2024 APA statistics report. Read more. |
Tax legislation approved and regulatory update | Treaties | 02 December 2025 | Updates to the OECD Model Tax Convention. Read more. |
Poland
Poland | |||
Administrative and case law | Income tax | 23 December 2025 | Remitter of dividends obligated to verify authenticity of ownership structure (Supreme Administrative Court decision). Read more. |
Tax legislation approved and regulatory update | Tax compliance | 23 December 2025 | Implementing regulations for national electronic invoicing (e-invoicing) system (KSeF). Read more. |
Proposed legislation | Various tax topics | 23 December 2025 | 2026 budget bill adopted by upper house of Parliament with amendments, various tax-related bills acted upon by president. Read more. |
| Tax legislation approved and regulatory update | Income tax | 17 December 2025 | Amendments to corporate income tax for banks and exemptions for investment funds. Read more. |
| KPMG publication | Various tax topics | 16 December 2025 | Senate passes amendments to cash individual income tax scheme and succession law, other tax developments. Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 03 December 2025 | Legislation passed by upper house of Parliament includes direct and indirect tax changes. Read more. |
| Administrative and case law | Income tax | 03 December 2025 | Summaries of recent Supreme Administrative Court decisions. Read more. |
| Administrative and case law | Various tax topics | 01 December 2025 | Summaries of recent Supreme Administrative Court decisions. Read more. |
Portugal
Portugal | |||
Tax legislation approved and regulatory update | Tax compliance | 05 December 2025 | Postponed mandatory use of qualified electronic signature (QES) and standard audit file for tax (SAF-T) accounting file requirements. Read more. |
Romania
Romania | |||
Tax legislation approved and regulatory update | Indirect tax | 22 December 2025 | Rules for special scheme for import Value Added Tax (VAT) declaration and payment. Read more. |
Tax legislation approved and regulatory update | Treaties | 22 December 2025 | Tax treaties with Andorra and UK ratified. Read more. |
Proposed legislation | Tax compliance | 22 December 2025 | Proposed amendments to tax procedure law submitted to Parliament. Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 18 December 2025 | Amendments to fiscal code and introduction of new logistics fee. Read more. |
| Administrative and case law | Various tax topics | 17 December 2025 | Compatibility of solidarity contribution with EU law (CJEU referral). Read more. |
San Marino
San Marino | |||
Tax legislation approved and regulatory update | Income tax | 02 December 2025 | General income tax reform including amendments relating to corporate taxation. Read more. |
Senegal
Senegal | |||
Tax legislation approved and regulatory update | Various tax topics | 17 December 2025 | Multinational enterprise (MNE) groups not required to file country-by-country reports for 2023 and 2024. Read more. |
Serbia
Serbia | |||
Tax legislation approved and regulatory update | Indirect tax | 29 December 2025 | Amendments to excise tax law include gradual increase in excise taxes on tobacco products. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 18 December 2025 | Amendments to electronic invoicing (e-invoicing) law. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 17 December 2025 | Amendments to tax procedure and tax administration adopted. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 16 December 2025 | Amendments to the law on electronic delivery notes. Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 12 December 2025 | Amendments to Value Added Tax (VAT) law adopted. Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 10 December 2025 | New green taxes effective January 1, 2026. Read more. |
| Tax legislation approved and regulatory update | Indirect tax | 09 December 2025 | Amendments to individual income tax and social security contributions. Read more. |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | Various tax topics | 05 December 2025 | Amendment to Financial Transaction Tax Act introduces new rules. Read more. |
Administrative and case law | BEPS Pillar 2 | 02 December 2025 | Domestic Minimum Top-up Tax (DMTT) information return template published. Read more. |
South Africa
South Africa | |||
Proposed legislation | Various tax topics | 17 December 2025 | Requirements for certain unlisted companies to qualify as a real estate investment trust (REIT). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 11 December 2025 | Implementation of cryptoasset reporting framework (CARF) and common reporting standard (CRS) amendments. Read more. |
Proposed legislation | Income tax | 05 December 2025 | Draft guidance on income tax exemption. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | Indirect tax | 03 December 2025 | VERI*FACTU invoicing system delayed to 2027. Read more. |
Administrative and case law | Income tax | 01 December 2025 | Extension to nonresidents of wealth tax liability limitation based on income (Supreme Court decisions). Read more. |
Sweden
Sweden | |||
Administrative and case law | Treaties | 19 December 2025 | Taxation under Sweden-UK treaty of dividends covered by UK foreign income and gains (FIG) rules (Tax Court advance ruling). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 05 December 2025 | Updated lists of reportable and participating jurisdictions for automatic exchange of financial account information. Read more. |
Proposed legislation | Income tax | 05 December 2025 | Tax measures in 2026 budget bill includes labour tax reductions, lower Value Added Tax (VAT) on food. Read more. |
| Tax legislation approved and regulatory update | Income tax | 02 December 2025 | Parliament approves amendments to interest deduction limitation rules. Read more. |
Switzerland
Switzerland | |||
Administrative and case law | Transfer pricing | 19 December 2025 | Implications of Zug case and Switzerland’s commitment to calendar year-based transfer pricing enforcement. Read more. |
Proposed legislation | Indirect tax | 10 December 2025 | Proposal to expand Value Added Tax (VAT) platform taxation rules to digital services. Read more. |
Administrative and case law | Transfer pricing | 10 December 2025 | Survey on application of control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks, focus on Switzerland. Read more. |
| Tax legislation approved and regulatory update | Various tax topics | 04 December 2025 | Amendments to Automatic Exchange of Information (AEOI) legislation to incorporate CARF and CRS 2.0. Read more. |
| Tax legislation approved and regulatory update | Income tax | 02 December 2025 | Extension of withholding tax exemption on "too-big-to-fail" instruments approved by National Council. Read more. |
Tanzania
Tanzania | |||
Tax legislation approved and regulatory update | Tax compliance | 15 December 2025 | Tax amnesty for remission of interest and penalties. Read more. |
Administrative and case law | Indirect tax | 20 December 2025 | Value Added Tax (VAT) liability upheld on performance grants (court decision). Read more. |
Ukraine
Ukraine | |||
Tax legislation approved and regulatory update | Income tax | 02 December 2025 | Expanded scope of Diia City tax incentive regime. Read more. |
Tax legislation approved and regulatory update | Treaties | 02 December 2025 | Notification of updates to Multilateral Instrument (MLI) positions. Read more. |
United Kingdom
United Kingdom | |||
Administrative and case law | Indirect tax | 22 December 2025 | Value Added Tax (VAT) costs deductible when professional fees directly linked to taxable sale (Supreme Court decision). Read more. |
Proposed legislation | Various tax topics | 11 December 2025 | Tax measures in Finance Bill 2025-2026. Read more. |
Proposed legislation | Various tax topics | 01 December 2025 | Tax measures in Autumn Budget 2025 include changes to Pillar Two rules and transfer pricing, digital services tax and diverted profits tax reform. Read more. |
Zimbabwe
Zimbabwe | |||
Proposed legislation | Various tax topics | 01 December 2025 | Direct and indirect tax proposals in 2026 budget. Read more. |
