International Tax Europe and Africa 2025
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 May and 31 May 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.
Albania
Albania | |||
Tax legislation approved and regulatory update | Indirect tax | 15 May 2025 | Tax authorities enforcing nonresident Value Added Tax (VAT) digital services rules. Read more. |
Austria
Austria | |||
Proposed legislation | Indirect tax | 20 May 2025 | Proposed changes to real estate transfer tax rules on share deals. Read more. |
Administrative and case law | Income tax | 15 May 2025 | Exclusion of nonresident investment funds from dividend withholding tax refunds compatible with EU law (CJEU judgment). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 05 May 2025 | Tax measures in 2025 draft budget law. Read more. |
Bahrain
Bahrain | |||
Tax legislation approved and regulatory update | Indirect Tax | 19 May 2025 | Exemption from customs duties for industrial materials. Read more. |
Bulgaria
Bulgaria | |||
Tax legislation approved and regulatory update | Various tax topics | 07 May 2025 | Tax measures in 2025 budget law. Read more. |
Czech Republic
Czech Republic | |||
Proposed legislation | Indirect tax | 20 May 2025 | Draft guidance on calculating floor area for Value Added Tax (VAT) purposes. Read more. |
Administrative and case law | Various tax topics | 20 May 2025 | Deductibility of asset repair costs, initiation of tax inspection, interest on refunds of customs duties. Read more. |
Denmark
Denmark | |||
Tax legislation approved and regulatory update | Indirect tax | 27 May 2025 | Amendment providing flexibility in Value Added Tax (VAT) deductions. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 13 May 2025 | Value Added Tax (VAT) registered entities subject to new digital bookkeeping requirements as of January 1, 2026. Read more. |
European Union
European Union | |||
Tax legislation approved and regulatory update | Various tax topics | 21 May 2025 | EU adopts 17th Russia sanctions package. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 May 2025 | DAC9 published in official journal. Read more. |
KPMG publication | BEPS Pillar 2 | 16 May 2025 | Policy note on tax incentives. Read more. |
Proposed legislation | Various tax topics | 16 May 2025 | Draft report on the impact of simple tax rules and tax fragmentation on European competitiveness. Read more. |
Proposed legislation | Various tax topics | 16 May 2025 | European Parliament Subcommittee holds hearing on green transition and competitiveness. Read more. |
Proposed legislation | Indirect tax | 14 May 2025 | Draft directive to incentivize the use of Value Added Tax (VAT) import one-stop-shop. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 12 May 2025 | European Commission issues consolidated list of “Classification Regulations”. Read more. |
Finland
Finland | |||
Proposed legislation | Income tax | 16 May 2025 | Finland’s Ministry of Finance announced the General Government Fiscal Plan for 2026–2029. Read more. |
France
France | |||
Tax legislation approved and regulatory update | Treaties | 19 May 2025 | Revised list of non-cooperative jurisdictions issued. Read more. |
KPMG publication | Treaties | 16 May 2025 | French tax authorities issue ruling on withholding tax and dividend arbitrage. Read more. |
Tax legislation approved and regulatory update | Income tax | 07 May 2025 | Updated tax residency rules for companies using domiciliation services. Read more. |
Germany
Germany | |||
KPMG publication | Indirect tax | 30 May 2025 | Economic and Financial Affairs Council announces agreement on draft directive to incentivize the use of Value Added Tax (VAT) import one-stop-shop, other VAT developments. Read more. |
KPMG publication | Income tax | 27 May 2025 | Interest required on withholding tax refunds (Federal Tax Court decision); other tax developments. Read more. |
Administrative and case law | Tax compliance | 14 May 2025 | FATCA reporting deadline is July 31, 2025. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 07 May 2025 | Updated template for group parent notification under Pillar Two law. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 02 May 2025 | Guidance on new transaction matrix transfer pricing document requirement, other tax developments. Read more. |
Administrative and case law | Transfer pricing | 27 May 2025 | Federal Tax Court (I R 41/21): Parallel Imports Can Lead to Hidden Profit Distribution. Read more. |
Administrative and case law | Income tax | 27 May 2025 | Federal Tax Court (I R 47/21): Permanent Establishment Under Tax Treaty Law of a Taxi Company in the Premises of a Taxi Radio Center. Read more. |
Administrative and case law | Income tax | 27 May 2025 | Federal Tax Court (I R 45/22): German AOA Rule (Section 1 (5) Foreign Transactions Tax Law) Is an Income Correction Rule and Not a Profit Determination Rule. Read more. |
Administrative and case law | Income tax | 27 May 2025 | Federal Tax Court (I R 23/21): Managing Holding Company as Controlling Company of a Tax Group. Read more. |
Administrative and case law | Income tax | 27 May 2025 | Federal Tax Court (VIII R 32/21): Interest on Withholding Tax on Dividends Not Refunded in Breach of European Law. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 27 May 2025 | Update: Coalition Agreement for a New Federal Government. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 01 May 2025 | Danish Value Added Tax (VAT) registered entities subject to new digital bookkeeping requirements. Read more. |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 16 May 2025 | Updated Pillar Two Guidance. Read more. |
Italy
Italy | |||
KPMG publication | Various tax topics | 16 May 2025 | Updated FATCA and common reporting standard guidance. Read more. |
Kenya
Kenya | |||
Proposed legislation | Various tax topics | 15 May 2025 | Tax proposals in Finance Bill 2025, including introduction of advanced pricing agreements. Read more. |
Latvia
Latvia | |||
Administrative and case law | Income tax | 13 May 2025 | Special tax regime for consumer credit service providers held constitutional (court decision). Read more. |
Lithuania
Lithuania | |||
Tax legislation approved and regulatory update | Tax compliance | 16 May 2025 | Updates to reporting rules under DAC7 published. Read more. |
Luxembourg
Luxembourg | |||
Administrative and case law | Treaties | 19 May 2025 | Interest-free loans treated as equity contributions; branch did not qualify as permanent establishment under Malaysia treaty (High Administrative Court decision). Read more. |
Moldova
Moldova | |||
Proposed legislation | Transfer pricing | 07 May 2025 | Amended rules for advance pricing agreements, proposed amendments to Value Added Tax (VAT) refund program for farming entities. Read more. |
Mozambique
Mozambique | |||
Tax legislation approved and regulatory update | Indirect tax | 13 May 2025 | New procedures for monthly reporting of Value Added Tax (VAT) invoices. Read more. |
Netherlands
Netherlands | |||
Proposed legislation | Income tax | 22 May 2025 | Draft legislation to replace “Box 3” (wealth tax) regime sent to lower house of Parliament. Read more. |
Administrative and case law | Income tax | 02 May 2025 | Taxpayers not subject to anti-abuse rule for nonresident taxation of personal holding companies (Supreme Court decisions). Read more. |
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OECD
OECD | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 22 May 2025 | Updated transfer pricing country profiles. Read more. |
Poland
Poland | |||
Proposed legislation | Income tax | 28 May 2025 | Deregulatory amendments to corporate and individual income tax laws approved by Council of Ministers. Read more. |
KPMG publication | Various tax topics | 22 May 2025 | Summaries of court decisions in Poland. Read more. |
Proposed legislation | Various tax topics | 15 May 2025 | Amendments to corporate income tax and Value Added Tax (VAT) laws passed by Council of Ministers. Read more. |
Administrative and case law | Income tax | 09 May 2025 | Joint and several liability of board member for company’s tax debts upheld (CJEU judgment). Read more. |
Proposed legislation | Tax compliance | 09 May 2025 | Draft updated guidance on cash registers. Read more. |
Proposed legislation | Various tax topics | 09 May 2025 | Proposed income tax and Value Added Tax (VAT) amendments. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 16 May 2025 | Pillar Two implemented in the Basque Country. Read more. |
Switzerland
Switzerland | |||
Proposed legislation | BEPS Pillar 2 | 19 May 2025 | Public consultation on global anti-base erosion (GloBE) information return. Read more. |
Administrative and case law | BEPS Pillar 2 | 07 May 2025 | Guidance on treatment of permanent establishments (PEs) under Pillar Two minimum tax rules. Read more. |
Ukraine
Ukraine | |||
Administrative and case law | Indirect tax | 07 May 2025 | Guidance on Value Added Tax (VAT) exemption for defense goods. Read more. |
United Kingdom
United Kingdom | |||
Administrative and case law | Tax compliance | 28 May 2025 | Guidance on cryptoasset reporting framework obligations for UK-based service providers. Read more. |
Administrative and case law | Income tax | 16 May 2025 | Treatment of distribution as dividend not of capital nature determined under foreign law (Court of Appeal decision). Read more. |
