E-News from KPMG’s EU Tax Centre

• European Commission: Recommendation on Savings and Investment Accounts
• European Commission: Commissioner Hoekstra answers parliamentary question on the introduction of a European digital tax
• Council: October 2025 update of the EU list of non-cooperative jurisdictions
• European Parliament: Resolution on the role of simple tax rules and tax fragmentation in European
• Denmark: Updated DAC7 reporting guidance for tax year 2024
• Denmark: Executive order issued outlining reporting obligations for crypto-asset services providers (DAC8)
• France: Pillar Two guidance published
• France: Notice on common errors made by taxpayers on Pillar Two filing
• Malta: Form published for the Final Income Tax Without Imputation Regulations
• German Federal Tax Court ruling on submission of e-mails and digital transfer pricing documents as part of tax audits

CJEU finds that it has no jurisdiction to interpret Slovak capital gains provisions in domestic reorganization

On July 21, 2025, an order issued by the Court of Justice of the European Union (CJEU or the Court) in case C-201/24 was published in the Official Journal of the EU. The Court found that it lacks jurisdiction to rule on questions referred by the Slovak Supreme Administrative Court concerning the compatibility of a national levy on capital gains with EU law.

The referring court had sought clarification on whether a national levy on capital gains arising from the transfer of assets between companies established within the same Member State was compatible with the EU Merger Directive (2009/133/EC), particularly Articles 4(1) and 9. The CJEU held that the case concerned a purely domestic situation with no cross-border element and therefore fell outside the scope of EU law. Consequently, the Court declined jurisdiction to answer the questions referred.

European Commission Recommendation on Savings and Investment Accounts

On September 30, 2025, the European Commission (the Commission or the EC) published a “Recommendation on increasing the availability of savings and investment accounts (SIA) with simplified and advantageous tax treatment” (the Recommendation).

The Recommendation encourages all Member States to establish SIAs in order to promote greater retail investor participation in capital markets. The European Commission invites Member States to consider and adopt a range of key design features, including user-friendliness (making the accounts easy to access and operate), as well as flexibility in terms of investing and divesting. Additionally, the EC recommends a wide range of measures to support the uptake of SIAs, from tax incentives that encourage retail investors to open and maintain an SIA, to initiatives that simplify tax compliance.

The Recommendation is non-binding on Member States but it is intended to serve as a blueprint for those Member States that wish to develop and implement SIAs.

For more details on the European Commission Recommendation, please refer to Euro Tax Flash Issue 568.

Commissioner Hoekstra answers parliamentary question on the introduction of a European digital tax

On July 10, 2025, a member of the European Parliament (MEP) submitted a question to the Commission following Canada's decision to repeal its digital services tax. In particular, the MEP requested the Commission’s views on this decision, a clarification on whether the EU is facing external pressure from third countries regarding its own proposal for a digital tax, and an update on the current state of play regarding digital taxation in Europe.

On September 29, 2025, Wopke Hoekstra, Commissioner for Climate, Net Zero and Clean Growth – who is also responsible for taxation, answered the question. With regard to the Canadian Government’s decision, Mr. Hoekstra noted that this is a sovereign policy matter and is therefore not for the European Commission to comment on. Mr. Hoekstra also noted that the EC continues to favor a multilateral solution on digital taxation.

The Commissioner noted that significant work has already been undertaken by the OECD as part of the two-Pillar solution. According to the Commissioner, despite the discussions on Pillar One being temporarily on hold, they will be resumed by the end of the year, once a solution on Pillar Two is found. Mr. Hoekstra’s answer referred in this context to the G7 statement on June 28, 2025, whereby a side-by-side agreement between Pillar Two and the US system is foreseen and welcomed. Mr. Hoekstra further noted that the EC will continue to engage with both the United States and other third countries in this respect and will liaise with Member States on the best way forward, should a global solution fail to materialize.

For previous comments made by Commissioner Hoekstra in this context, please refer to E-News Issue 214. 

October 2025 update of the EU list of non-cooperative jurisdictions

On October 10, 2025, the Economic and Financial Affairs Council of the EU (ECOFIN Council) adopted conclusions on the EU list of non-cooperative jurisdictions (Annex I) and the state of play with respect to commitments taken by cooperative jurisdictions to implement tax good governance principles (Annex II – so called “grey list”).

No changes were made to Annex I of the EU list of non-cooperative jurisdictions, which continues to include the following eleven jurisdictions: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, the Russian Federation, Samoa, Trinidad and Tobago, the US Virgin Islands and Vanuatu.

In addition, the Council agreed to remove Vietnam from Annex II (the grey list), as it had fulfilled its previous commitments, and to add four other jurisdictions – Greenland, Jordan, Montenegro, Morocco.

The grey list now includes the following eleven jurisdictions: Antigua and Barbuda, Belize, the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, the Seychelles and Türkiye.

For more information, please refer to Euro Tax Flash Issue 569.

Council conclusions on tax incentives to support the Clean Industrial Deal

In its October 10 meeting, the ECOFIN Council also approved its conclusions on the recommendations issued by the European Commission on July 2, 2025, regarding tax incentives to support the Clean Industrial Deal (the Conclusions).

In this context, the Council welcomes the EC’s recommendation on tax incentives to support the Clean Industrial Deal. The Conclusions note that tax incentives should be seen as one possible element to be considered by each Member State as part of the evolving policy mix to support clean energy development, industrial decarbonization, and the advancement of clean technologies.

In its Conclusions, the Council also recognizes that Member States have different corporate tax regimes that need to be considered when determining the policy on tax incentives such as those set out in the Commission's recommendations. The Conclusions stress that, in the absence of binding rules at EU level, competence in the field of taxation lies solely with the Member States and underline the importance of flexibility in their application. Whilst noting that some Member States may choose to consider the principles and tax incentives proposed in the Commission’s recommendation, the Council emphasizes that each Member State remains free to design, implement, and apply such incentives in line with its own national circumstances, while also taking into account possible budgetary impacts.

During the public session of the ECOFIN Council meeting, the European Commission held a presentation on its proposal for a system of EU own resources, which was followed by an exchange of views between the Member States.

For more information, please refer to Euro Tax Flash Issue 570.

European Parliament adopts resolution on the role of simple tax rules and tax fragmentation in European competitiveness

On October 9, 2025, the European Parliament adopted a resolution on simple tax rules and tax fragmentation, aimed at improving European competitiveness (the Resolution).

The Resolution stresses the need for simpler, predictable, and better-coordinated tax systems across the EU to strengthen competitiveness, reduce compliance burdens, and boost sustainable growth, whilst preserving Member States’ fiscal sovereignty.

Key takeaways include:

• Taxation and the business environment: The Resolution stresses that simpler and more predictable tax rules are crucial for a competitive and fair EU business environment. It warns that complex and fragmented tax systems deter investment and disproportionately burden small and medium size companies (SMEs). The European Parliament calls for greater tax coordination across Member States, while respecting national sovereignty.
• Competitiveness and economic growth: The Parliament welcomes the European Council conclusions on the New European Competitiveness Deal, but expresses regret that taxation was overlooked. The Resolution calls for better tax cooperation within the EU, reducing fragmentation and increasing simplification, which are seen are essential to strengthening Europe’s competitiveness. The Parliament also notes that future EU tax initiatives should prioritize administrative simplification, the elimination of overlapping rules, and consistent interpretation of tax legislation across Member States. Finally, the Resolution highlights that well-designed, transparent tax incentives can promote investment and development, particularly in disadvantaged regions, provided they align with EU State Aid rules, the OECD’s Pillar Two framework, and the EU’s climate goals.
• Tax simplification and digitalization: The Resolution calls for the development of a comprehensive SMEs tax toolkit that would include practical templates, automated filing options, and digital support to ease administrative burdens. Common implementation tools, such as standardized reporting formats and shared best practices between national tax administrations, are encouraged. The resolution further calls for the creation of an EU Tax Data Hub to facilitate the automatic exchange of tax information and reduce administrative burdens. Finally, the Parliament reiterates its position on the proposed Head Office Tax system for SMEs, the ‘Unshell’ directive proposal, and the debt-equity bias reduction allowance (DEBRA). The Resolution notes the ongoing work on the Business in Europe: Framework for Income Taxation (BEFIT) proposal and calls for an effective and balanced approach that benefits all Member States, respects subsidiarity, and aligns with the implementation of the OECD’s Pillar Two rules.
• OECD Pillars One and Two, and international taxation: the Resolution reiterates the EU’s strong commitment to implementing the OECD/G20 Inclusive Framework two-pillar approach, whilst noting the January 2025 U.S. Executive Order declaring that the OECD Global Tax Deal has no force in the United States. It urges the Commission to prioritize work to maintain and protect the agreement, prevent harmful tax competition, and safeguard EU interests, including preparing contingency plans and taking prompt action to protect the integrity of the Pillar Two Directive. The Resolution also welcomes the transposition of Pillar Two into national law, and calls for legal clarity, especially regarding differences between the OECD Model Rules and Member State implementation. The Parliament expects the finalization of administrative guidance to provide certainty to impacted companies and further developments on safe harbours to ease compliance (such as the development of a permanent safe harbour). Finally, the Parliament acknowledges the OECD’s publication of the Multilateral Convention in October 2023 for implementing Amount A of Pillar One and the ongoing negotiations, and calls on the Commission to assess the potential effects of a Digital Services Tax.
• Addressing tax barriers: The resolution supports exploring the idea of a voluntary ‘28th tax regime’ to simplify taxation for innovative start-ups and facilitate investment across Member States. The Parliament calls on the Commission to identify and address tax barriers that cause double taxation and to produce an action plan for tackling them.
• Combating tax evasion and avoidance, and aggressive tax planning: The European Parliament reaffirms its commitment to combating tax evasion, avoidance, and aggressive tax planning to ensure fairness and protect public revenues. The Parliament recognizes the importance of existing frameworks like the Directive on Administrative Cooperation (DAC) and the Anti-Tax Avoidance Directive (ATAD) in improving transparency but stresses the need for their simplification and alignment with global tax standards, to ensure coherence and legal certainty. The resolution calls for strengthened cooperation between the European Public Prosecutor's Office and Eurofisc, as well as improved coordination among Member States, to enhance cross-border investigations and information exchange.
• Taxation and innovation: The Parliament stresses that innovation and R&D tax incentives are vital for growth and competitiveness but must be well-targeted, cost-effective, and regularly evaluated. It calls on the Commission to study their impact, ensure coordination among Member States, and explore tools such as transferable tax credits and super deductions to better support start-ups. These incentives should boost investment without enabling tax avoidance and must remain fully consistent with EU State Aid rules to preserve fair competition and legal certainty across the internal market.

Resolutions adopted by the European Parliament are not binding on the Council and the European Commission but must be considered by the Commission and Member States when proposing or agreeing on new rules. 

List of signatories of the GIR MCAA updated

On October 8, 2025, the OECD updated the list of jurisdictions that have signed the GloBE Information Return Multilateral Competent Authority Agreement (GIR MCAA) to include Finland, Liechtenstein, Norway and South Africa which signed the Agreement on September 30, September 29, September 1, and October 2, 2025 respectively.

The list of 21 signatories now includes Austria, Belgium, Denmark, Finland, France, Germany, Ireland, Italy, Japan, South Korea, Liechtenstein, Luxembourg, the Netherlands, New Zealand, Norway, Portugal, Slovakia, South Africa, Spain, Switzerland and the UK.

For previous coverage on the GIR MCAA list of signatories, please refer to E-News Issue 218. 

Clarifications on the minimum participation requirement in Belgium’s dividend received deduction

On October 3, 2025, the Federal Service for Finance in Belgium published a circular (available in French and Dutch) clarifying the main aspects of the changes brought in July 2025 to the Belgian dividend participation exemption – or the so-called dividends received deduction regime (DRD).

Under the DRD, dividends that are eligible for the tax benefits prescribed by the Parent Subsidiary Directive (PSD) are initially included in the tax base of the recipient company, followed by a 100 percent deduction. Based on the July changes, the participation exemption rules remain unchanged for holdings of at least 10 percent of a company’s capital. However, for participations valued at EUR 2.5 million or above but representing less than 10 percent, an additional condition now applies: the participation must be classified as a financial fixed asset, unless the investor is a small enterprise. For more details, please refer to E-news Issue 215.

Key clarifications include:

• Definition of financial fixed assets: The circular clarifies that financial fixed assets are defined by company law and include holdings in affiliated companies, entities over which the company exercises significant influence, and other strategic business relationships.
• Purpose and long-term nature: The circular highlights that both the purpose and duration of the holding are key factors. Only strategic, long-term holdings qualify as financial assets, while assets held solely for investment or short-term returns do not.
• Application to other tax exemptions: The circular clarifies that the financial fixed asset requirement also applies to the exemption from the withholding tax on dividends paid to non-resident companies and to the exemption for capital gains on shares.

The clarifications brought by the circular apply to tax years starting in 2026 and onwards.

Denmark updated DAC7 reporting guidance for tax year 2024

On July 2, 2025, the Danish tax authority published an updated guidance on the practical application of the Amending Directive to the 2011 Directive on Administrative Cooperation (DAC7).

The guidance outlines the mandatory reporting obligations for platform operators regarding sellers’ income on digital platforms for the 2024 tax year. It covers the relevant rules, submission deadlines, and procedures for filing and amending reports.

Key updates include:

• Danish car and vacation rental platforms must report gross rental income for the calendar year corresponding to the rental period, even if payment to the landlord occurs after year-end (e.g., rentals ending between Christmas and New Year’s).
• If a rental period overlaps at the end of the year, the income should not be split between years. Instead, it can be assigned either to the year in which the rental period starts or, if payment is made later, to the year in which the landlord receives the income.

Danish government publishes an executive order outlining reporting obligations for crypto-asset service providers (DAC8)

On September 10, 2025, the Danish government issued Executive Order No. 115 published in the Official Gazette on October 2, 2025, outlining the new reporting obligations for crypto-asset service providers under Denmark’s implementation of Directive (EU) 2023/2226 on administrative cooperation in taxation (DAC8).

The order was adopted under the authority of an April 29, 2025, bill transposing DAC8 into Danish law and supplements it. The order introduces comprehensive reporting and due-diligence requirements for crypto-asset service providers operating in Denmark. The rules apply to both companies and individuals that exchange or transfer crypto assets for, or on behalf of, users who are domiciled, registered, or otherwise have a business presence in Denmark. For previous coverage, please refer to E-news Issue 213.

Providers are required to collect and report detailed information about users and transactions to the Danish Tax Agency, including each customer’s name, address, tax-identification number, date of birth, and transaction data. They must also verify information on tax residency and maintain updated records of customer identity. In addition, providers must submit updated self-declarations whenever relevant circumstances change and are expected to promptly notify the tax authorities if users fail to update their information. Failure to report, provide complete information, or comply with the order’s due diligence requirements may result in administrative fines, daily penalties, or suspension of registration.

The executive order provides the domestic legal framework for enforcing the OECD’s Crypto-Asset Reporting Framework (CARF) through DAC8 and clarifies the scope of Denmark’s participation in the automatic exchange of information on crypto-assets and e-money. Reporting will cover all transactions concluded on or after January 1, 2026, with the first exchange of information scheduled for 2027.

Pillar Two guidance published

On October 8, 2025, the French tax authorities issued new guidance on the French Pillar Two legislation. The guidance provides clarifications and examples on different aspects of the Pillar Two rules in France, aligned with the GloBE Model Rules and Commentary, including:

• Various definitions and wording clarifications.
• Scope of application and territoriality, covering in particular:
• Entities in scope (e.g., revenue threshold test, period of reference, specific provisions in case of mergers or demergers).
• Excluded entities.
• Territoriality rules (e.g., stand-alone entities, intermediate entities, permanent establishments, double resident entities). 

The French tax authorities have announced that additional guidance is being drafted, focusing on the following topics: application of safe harbour rules, calculation of the effective tax rate, calculation of top-up tax liability, application of charging mechanisms, transitory rules as well as clarifications on filing and payment.

For previous coverage on the French Pillar Two legislation, please refer to E-News Issue 207.

France issues notice on common errors made by taxpayers on Pillar Two filing

As part of the first 2025 reporting campaign, the French tax authorities released a notice on the common errors made by French entities in scope of Pillar Two when filing the reporting form, which groups in scope of country-by-country reporting requirements and/or the Pillar Two must file annually together with their corporate tax returns. The notice also includes additional filing instructions.

The main recurrent errors noted include:

• Incomplete declarations, e.g., failure to identify the Ultimate Parent Entity (UPE) or the designated filing entity for the GloBE Information Return (GIR).
• Entities that wrongly designate themselves as the UPEs.
• Designation of a French entity to file the GIR without indicating this within its own form.
• The designation of a foreign entity, instead of a French one, to file and pay the additional tax.
• Other errors, including incorrect country codes or tax identification numbers.

These errors could have substantial consequences and may result in penalties. The French tax authorities therefore strongly encourage taxpayers to promptly submit a corrected form to rectify any inaccuracies.

For previous coverage of the Pillar Two reporting requirements in France, refer to E-News Issue 218.

Lithuania clarifies updated commentary on the reformed law on CIT

On September 30, 2025, the Lithuanian State Tax Inspectorate updated the commentary on the reformed law on Corporate Income Tax (CIT). The commentary specifies which tax rates apply to different types of income, entities, and situations and provides details on eligibility and conditions for reduced tax rates and exemptions from 2026 tax year onwards.

Key takeaways include:

• Standard CIT rate: The standard rate increases to 17 percent for Lithuanian companies and permanent establishments. Entities with annual income up to EUR 300,000 may qualify for zero percent tax for the first two years and seven percent tax for subsequent years. Individual ownership and continuity for the entity's participants are required.
• Taxation of foreign entities: Certain income earned by foreign companies without a permanent establishment in Lithuania is subject to a tax rate of 10 percent.
• Dividends: Dividends are generally taxed at 17 percent.
• Improperly used donations: Donations misused or exceeding EUR 17,500 from one donor are taxed at 17 percent.
• Cooperative Entities: Cooperative entities pay seven percent tax when half of their income is from agricultural activities.
• Patented assets: Assets that are self-developed, patented or copyright-protected are taxed at seven percent.

For previous coverage on the CIT reform, please refer to E-News Issue 214.

Form published for the Final Income Tax Without Imputation Regulations 

On October 9, 2025, the Malta Tax and Customs Administrations published the election form for the Final Income Tax Without Imputation Regulations (“Regulations)”, published on September 2, 2025. Based on the Regulations, an entity may elect to be taxed on its chargeable income at a 15 percent rate, as an alternative to the standard rules of the Maltese Income Tax Act, namely without the application of the imputation system.

Main takeaways include:

• The election may be made in respect of income accruing to or derived by the entity in the fiscal year preceding the year of assessment 2025 and subsequent years, i.e., as from basis year ending on December 31, 2024. For those companies wishing to apply for the election for year of assessment 2025, the election must be submitted by November 28, 2025.
• Once this election is made, the 15 percent final tax will be applicable for at least five consecutive years, after which the company may apply to revert to taxation under the standard provisions of the Maltese Income Tax Act.
• The form must be signed by the director signing on behalf of the company and must be submitted to the Malta Tax and Customs Administrations via the general e-mail address.

Please note that Malta elected for the deferred application of the IIR and UTPR and only transposed administrative requirements necessary for the functioning of the EU Minimum Tax Directive.

For our previous coverage on the Regulations, please refer to E-News Issue 217.

STTR implementing regulation published in the Official Gazette

On September 26, 2025, the San Marino National Council published in the Official Gazette a decree ratifying the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI).The STTR allows developing countries to tax certain outbound intra-group payments if the recipient's jurisdiction has a corporate tax rate below 9 percent, with some preferential tax adjustments. San Marino previously signed the STTR MLI on September 19, 2024, including the six tax treaties that should be covered by the STTR MLI.

The decree entered into force on the day of publication in the Official Gazette.

For more information on the STTR, please refer to E-News Issue 201.

German Federal Tax Court ruling on submission of e-mails and digital transfer pricing documents as part of tax audits 

On April 30, 2025, the German Federal Tax Court (the Court) ruled that e-mails may qualify as commercial or business letters under German document retention laws and, therefore, can be requested by the tax authorities during external audits. The Court further confirmed that digital documents relating to group transfer pricing are also relevant and may be subject to disclosure. However, whilst the tax authorities are entitled to request all tax-related e-mails, they cannot require taxpayers to prepare a new, comprehensive ‘general journal’ that would include non-tax-related content.

The plaintiff, a company tax resident in Germany, challenged a request by the German tax authorities during an external audit to submit commercial and business correspondence, including the general journal. The dispute arose in connection with a "Sales and Marketing Services Agreement" (SMS Agreement) entered into with a group company based outside Germany. As part of their audit, the German tax authorities sought digital access to business letters and other tax-relevant documentation, specifically excluding private correspondence of employees and purely internal communications. However, they expressly requested correspondence between the plaintiff and the foreign group company. If these documents were available electronically, the plaintiff was instructed to provide a general journal containing details such as the sender and recipient (including cc and bcc recipients), the subject, and any attachments to the emails.

The Court ruled that the German tax authorities were entitled to request all emails related to the preparation, conclusion, and execution of the SMS Agreement, including those pertaining to transfer pricing documentation, whilst excluding private and purely internal communications. The Court found that a general request for all business correspondence during the audit period was permissible, particularly in light of the tax authorities’ limited knowledge of the specific documents involved. The Court further noted that the request was sufficiently specific, as it referenced the SMS Agreement and tax-relevant correspondence, and therefore did not require additional limitations such as specific search terms, designated employees, or shorter time frames.

Additionally, the Court confirmed that the German tax authorities were justified in requesting emails related to the plaintiff’s transfer pricing documentation, as such correspondence qualifies as ‘other documents’ relevant for taxation purposes. The Court clarified that emails concerning the preparation, conclusion, and implementation of the SMS Agreement – including those relating solely to ‘fulfilment actions’, must be retained and submitted. In the Court’s view, the existence of special documentation requirements for transfer pricing does not exempt taxpayers from the obligation to retain general documents, such as emails, when they contain tax-relevant information. Additionally, the Court found the tax authorities’ request (with the exception of the general journal requirement) to be proportionate, as it allowed the plaintiff an ‘initial qualification right’ – the discretion to determine which emails or documents were relevant for the external audit.

However, the Court rejected the tax authorities’ demand for a digital general journal containing data on all email correspondence, finding that there was no legal basis for such a request. In the Court’s view, this demand would require the plaintiff to submit its entire email correspondence, regardless of whether there was a retention obligation for any individual email. The Court concluded that such a broad request, which would include emails without tax relevance, exceeded the scope of the tax authorities’ powers to request electronic documents.

For more details, please refer to a tax alert prepared by KPMG in Germany. 

High Court judgment on Danish dividend tax refund claims

On October 2, 2025, the High Court of Justice of England and Wales (the Court) issued its judgment in case [2025] EWHC 2364, which consolidated five representative claims brought by the Danish customs and tax administration (SKAT) out of a wider set of refund proceedings linked to alleged cum-ex trading schemes. The Court examined four sample trading structures to illustrate how the purported refund arrangements operated in practice. Each model captured a variant of the trading and custodial chains used to support dividend-tax refund applications, which the Court analyzed to assess whether misrepresentations could have included SKAT’s payments.

The proceedings form part of Denmark’s wider response to dividend tax refund claims linked to cum-ex equity trading, and concern whether the plaintiff was deceived by misrepresentations submitted in support of refund applications. The claims at issue relate to Danish dividend tax refund payments made over several years, with SKAT alleging that it was wrongfully induced to pay based on documents and statements supporting the refund claims. The case is notable for its scale and complexity, with SKAT identifying 4,170 Danish dividend tax refund claims, totaling DKK 12.091 billion (approximately EUR 1.62 billion), and alleging that these were connected to cum-ex trading models designed to generate or support refund entitlements where none existed under Danish law. The plaintiff suspended all refund payments in August 2015 following a tip-off, and subsequently initiated litigation to recover amounts paid and establish liability among various defendants.

The Court addressed multiple causes of action advanced by SKAT, including deceit, conspiracy, negligence, and unjust enrichment, each framed around whether SKAT was in fact misled by representations embedded in the refund claims and whether defendants orchestrated or participated in unlawful schemes. The court did not accept claims made by some of the defendants that they had a reasonable belief that their cum-ex trading models generated valid tax refund claims under Danish tax law. However, according to the court, that does not prove the deceit alleged by SKAT occurred – the court concluded that SKAT failed to establish that it had been misled by misrepresentations made through the refund claim documents. The judgment emphasizes that SKAT’s processes for assessing and paying claims did not support a finding that the alleged misrepresentations were causative of the payments, and therefore the deceit claim was dismissed. On conspiracy, SKAT’s claim that defendants conspired to defraud SKAT through the submission of false or misleading refund claims was found to be unsupported by sufficient evidence; the court dismissed the conspiracy allegations.

SKAT also pursued negligence claims, including negligent misstatement against certain defendants, on the basis that SKAT relied on representations made in the claims to its detriment. The court determined that SKAT did not prove that it was misled into making payments by the alleged misrepresentations and dismissed the negligence claims accordingly. As to unjust enrichment, SKAT argued that defendants were unjustly enriched by receiving refunds to which there was no entitlement under Danish law. The Court dismissed SKAT’s unjust enrichment claims, concluding that the pleaded grounds were not established on the evidence presented.

The judgment records that all claims in which liability was disputed were dismissed. 

Implications of the G7 statement for Pillar Two compliance – October 1, 2025 (two sessions)

On October 1, 2025, a panel of KPMG professionals discussed the implications of the G7 statement from a 2024/2025 Pillar Two compliance perspective.

On June 28, 2025, the G7, comprising of Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States, released a statement which outlines a shared understanding of a “side-by-side” solution to US concerns regarding Pillar Two.

The G7 statement leaves a lot of unanswered questions and provides no certainty on when the changes it proposes to the application of Pillar Two to US-parented groups will be enacted in countries’ national laws, creating uncertainty for businesses about how they should be approaching Pillar Two from a compliance perspective.

The replay of the webcast is available on the event page.

European financial services tax perspectives – October 22, 2025

On October 22, 2025, a panel of KPMG professionals will share their insights on some of the latest EU proposals that are likely to affect (A) asset managers, banks and insurers.

The European tax landscape is shifting fast and financial services institutions are feeling the impact. With BEP Pillar 2 implementation underway, firms are facing new challenges around global minimum taxation, substance requirements, and much more. At the same time, EU directives are reshaping compliance expectations, while local tax authorities ramp up enforcement. Add to that the growing focus transformation and digitalization it’s clear that tax leaders should be seeking to stay agile.

KPMG tax specialists will take a closer look at:

• Regional landscape – with several governments across the region looking to set out their fiscal plans for the year ahead, what is the potential impact on future tax policy across financial services
• EU Savings and Investment Union (SIU): the impact of the SIU and its strategies to boost retail investor participation across the EU. Key insights from Luxembourg, Ireland and the UK.
• Beneficial ownership and substance: key insights from a recent KPMG survey on trends across the EU and the practice of local tax authorities. Spotlight on France, Ireland and Germany.

Please access the event page to register.

Key links

• Visit our website for earlier editions.