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 September and 30 September 2025.
International Tax Europe and Africa September 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.
Austria
Austria | |||
Administrative and case law | Income tax | 30 September 2025 | Court of Justice of the European Union (CJEU) referral on tax treatment of distributions made by private foundations to nonresident beneficiaries (Austria). Read more |
Proposed legislation | Income tax | 08 September 2025 | Draft research premium guidelines 2025 & other recent tax developments. Read more |
Belgium
Belgium | |||
Administrative and case law | Tax compliance | 30 September 2025 | Boundaries of tax investigations and data requests (Court of Appeal decision). Read more |
| Administrative and case law | Transfer Pricing | 29 September 2025 | Transfer pricing dispute concerning royalties, factoring fees, and interest deductions (court decision). Read more |
| Administrative and case law | Income tax | 29 September 2025 | Annulment of key provisions of Cayman Tax 2.1 (Constitutional Court decision). Read more |
| Administrative and case law | Income tax | 18 September 2025 | Recovery of wage tax and withholding tax on dividends, interest, or royalties. Read more |
| Administrative and case law | Various tax topics | 17 September 2025 | Beneficial ownership not required for withholding tax exemption under Belgian law implementing Eurpean Union (EU) interest-royalty directive (court decision). Read more |
Czech Republic
Czech Republic | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 17 September 2025 | Amendments to Pillar Two rules signed by president. Read more |
Tax legislation approved and regulatory update | Income tax | 11 September 2025 | Legislation including changes to research and development (R&D) allowances, other income tax changes passed by Parliament. Read more |
Proposed legislation | Income tax | 05 September 2025 | Proposed changes to R&D allowances. Read more |
Denmark
Denmark | |||
Tax legislation approved and regulatory update | Income tax | 26 September 2025 | Updated DAC7 reporting guidance. Read more |
Estonia
Estonia | |||
Tax legislation approved and regulatory update | Income tax | 10 September 2025 | Amendments to motor vehicle tax. Read more |
Ethiopia
Ethiopia | |||
Tax legislation approved and regulatory update | Income tax | 19 September 2025 | Tax amendments passed by House of Peoples’ Representatives. Read more |
European Union
European Union | |||
KPMG publication | Various tax topics | 30 September 2025 | Update on European Trust and Cooperation Approach to transfer pricing, Business in Europe: Framework for Income Taxation proposal, creation of Capital Markets Union. Read more |
| Administrative and case law | Indirect tax | 29 September 2025 | Court of Justice of the European Union (CJEU) referrals on third-party liability for Value Added Tax (VAT) debts of dissolved company, classification of decorative infused paper sheets under combined nomenclature (Bulgaria). Read more |
| Administrative and case law | Indirect tax | 18 September 2025 | Court of Justice of the European Union (CJEU) referral on Value Added Tax (VAT) group ownership requirements (Denmark). Read more |
| Administrative and case law | Indirect tax | 18 September 2025 | Court of Justice of the European Union (CJEU) Advocate General (AG) opinion on Value Added Tax (VAT) treatment of points earned under loyalty program (Sweden). Read more |
| Proposed legislation | Indirect tax | 17 September 2025 | European Commission (EC) proposes suspension of trade provisions with Israel. Read more |
| Administrative and case law | Income tax | 17 September 2025 | Court of Justice of the European Union (CJEU) referral on tax free treatment of partial division under merger directive (Poland). Read more |
| Administrative and case law | Treaties | 17 September 2025 | Court of Justice of the European Union (CJEU) referral on interpretation of tax dispute resolution mechanisms directive (Latvia). Read more |
| Administrative and case law | Indirect tax | 12 September 2025 | Sale of in-game gold are taxable digital services (Court of Justice of the European Union (CJEU) Advocate General opinion). Read more |
| Administrative and case law | Transfer Pricing | 04 September 2025 | Intra-group payments under the transactional net margin method subject to Value Added Tax (VAT) (Court of Justice of the European Union (CJEU) judgment). Read more |
| Proposed legislation | Indirect tax | 02 September 2025 | European Commission (EC) proposes tariff reductions to implement European Union (EU)-United States (US) deal. Read more |
Finland
Finland | |||
Tax legislation approved and regulatory update | Tax compliance | 15 September 2025 | Update on extension of temporary relief for missing U.S. tax identification numbers (TINs). Read more |
France
France | |||
Proposed legislation | Indirect tax | 30 September 2025 | Proposed simplification and tolerance measures for electronic invoicing (e-invoicing) and electronic reporting (e-reporting) reform. Read more |
Administrative and case law | Indirect tax | 15 September 2025 | Digital services tax upheld (DST) (Constitutional Court decision). Read more |
Tax legislation approved and regulatory update | Tax compliance | 12 September 2025 | Measures for mandatory electronic invoicing (e-invoicing) and e-reporting. Read more |
Germany
Germany | |||
Proposed legislation | BEPS Pillar 2 | 30 September 2025 | Draft amendments to Pillar Two rules adopted by Federal Cabinet & draft bill to implement DAC8 & other tax developments. Read more |
Administrative and case law | Transfer Pricing | 16 September 2025 | Legislation incorporating authorized OECD approach to permanent establishments (PEs) not an independent rule for determining PE profit (Federal Fiscal Court decision). Read more |
Proposed legislation | Tax compliance | 15 September 2025 | Draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8). Read more |
Global
Global | |||
KPMG publication | Various tax topics | 22 September 2025 | Global Transfer Pricing Review. Read more |
Greece
Greece | |||
Administrative and case law | Tax compliance | 22 September 2025 | Procedure to claim incentives for early implementation of electronic invoicing. Read more |
Tax legislation approved and regulatory update | Tax compliance | 17 September 2025 | Compliance deadlines for e-invoicing. Read more |
Administrative and case law | Income tax | 04 September 2025 | Summary of a recent Supreme Administrative Court decision. Read more |
Administrative and case law | Indirect tax | 04 September 2025 | Value Added Tax (VAT) on commercial pleasure vessels based on expiration of license. Read more |
Hungary
Hungary | |||
Administrative and case law | Tax compliance | 11 September 2025 | Tax authority announces stricter approach to online invoice reporting errors. Read more |
Ireland
Ireland | |||
Administrative and case law | Tax compliance | 04 September 2025 | Updated guidance on adoption of directive on administrative cooperation in taxation (DAC). Read more |
Isle of Man
Isle of Man | |||
Administrative and case law | BEPS Pillar 2 | 11 September 2025 | Guidance on Pillar Two global minimum tax online service. Read more |
Italy
Italy | |||
Tax legislation approved and regulatory update | Income tax | 19 September 2025 | Implementation of corporate income tax relief under Budget Law 2025. Read more |
Administrative and case law | BEPS Pillar 2 | 08 September 2025 | Notification form for global anti-base erosion (GloBE) information return (GIR). Read more |
Kenya
Kenya | |||
Administrative and case law | Indirect tax | 19 September 2025 | Commissions earned by payment service provider exempt from Value Added Tax (VAT) (High Court decision). Read more |
Latvia
Latvia | |||
Proposed legislation | Various tax topics | 17 September 2025 | Amendments to tax law aimed at reducing administrative burdens. Read more |
Luxembourg
Luxembourg | |||
Tax legislation approved and regulatory update | Income tax | 25 September 2025 | Extension of 2024 housing package tax measures. Read more |
Mali
Mali | |||
Tax legislation approved and regulatory update | Indirect tax | 04 September 2025 | New taxes on telecommunication services and mobile money transactions. Read more |
Malta
Malta | |||
Tax legislation approved and regulatory update | Income tax | 17 September 2025 | Regulations on 15% “elective tax” published. Read more |
Mauritius
Mauritius | |||
Administrative and case law | Transfer Pricing | 16 September 2025 | Assessment Review Committee upholds arm's length principle for domestic interest-free loans. Read more |
Moldova
Moldova | |||
Tax legislation approved and regulatory update | Indirect tax | 18 September 2025 | Value Added Tax (VAT) rules for electricity and natural gas supplies. Read more |
Administrative and case law | Transfer Pricing | 18 September 2025 | Annual submission of transfer pricing file no longer required. Read more |
Netherlands
Netherlands | |||
Proposed legislation | Treaties | 19 September 2025 | Proposal to mitigate interest on underpaid tax when mutual agreement procedure (MAP) conducted. Read more |
Proposed legislation | Various tax topics | 18 September 2025 | Government submits 2026 Tax Plan to Parliament, including Pillar Two changes and implementation of DAC9. Read more |
Administrative and case law | BEPS Pillar 2 | 08 September 2025 | Question and answer (Q&A) document on Minimum Tax Act 2024. Read more |
OECD
OECD | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 25 September 2025 | Albania signs multilateral convention implementing Pillar Two subject to tax rule. Read more |
Administrative and case law | BEPS Pillar 2 | 18 September 2025 | Pillar Two transitional qualified status achieved by Jersey and Isle of Man. Read more |
KPMG publication | BEPS Pillar 2 | 17 September 2025 | Updated list of signatories to the GloBE Information Return (GIR) Multilateral Competent Authority Agreement (MCAA). Read more |
Tax legislation approved and regulatory update | Various tax topics | 11 September 2025 | Report on tax policy reforms introduced or announced in 2024 by Organisation for Economic Co-operation and Development (OECD) countries. Read more |
Administrative and case law | BEPS Pillar 1 | 08 September 2025 | Revised framework for exchange of information on tax rulings under base erosion and profit shifting (BEPS) Action 5. Read more |
Poland
Poland | |||
Administrative and case law | Indirect tax | 25 September 2025 | New Krajowy System e-Faktur (KSeF) manual to support mandatory e-invoicing implementation. Read more |
Administrative and case law | Indirect tax | 16 September 2025 | Taxable Value Added Tax (VAT) base for voucher & use of motor vehicles for business versus personal use for VAT purposes (Supreme Administrative Court decisions). Read more |
KPMG publication | Various tax topics | 16 September 2025 | Consultations on Pillar Two forms and anti-avoidance regulations & other tax developments. Read more |
Administrative and case law | Income tax | 09 September 2025 | Short-term rental permissible activity for family foundation & no right to issue corrective invoice after expiration of statute of limitations. Read more |
Administrative and case law | Indirect tax | 09 September 2025 | Value Added Tax (VAT) guidelines for deposit-refund system. Read more |
Tax legislation approved and regulatory update | Indirect tax | 09 September 2025 | Legislation mandating national electronic invoicing (e-invoicing) system (KSeF) and aligning tax regulations with new forms of company reorganization promulgated. Read more |
Administrative and case law | Income tax | 02 September 2025 | Guidance on liability of management board members for company’s tax assessments. Read more |
Administrative and case law | Income tax | 02 September 2025 | Summaries of recent Supreme Administrative Court decisions. Read more |
Tax legislation approved and regulatory update | Various tax topics | 02 September 2025 | Council of Ministers preliminary approves 2026 budget bill, including increase in corporate tax for banking sector. Read more |
Portugal
Portugal | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 17 September 2025 | Pillar Two notification form and instructions. Read more |
Romania
Romania | |||
Proposed legislation | Indirect tax | 18 September 2025 | Proposal to repeal Value Added Tax (VAT) exemption for non-governmental organizations (NGOs). Read more |
Serbia
Serbia | |||
Administrative and case law | Indirect tax | 03 September 2025 | Updates to system of electronic invoicing (e-invoicing). Read more |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | Various tax topics | 30 September 2025 | Third package of consolidation measures approved by Parliament. Read more |
Tax legislation approved and regulatory update | Income tax | 16 September 2025 | Recent developments affecting tax depreciation and deductions for various business sectors. Read more |
Tax legislation approved and regulatory update | Various tax topics | 16 September 2025 | Guidance on financial transaction tax. Read more |
Tax legislation approved and regulatory update | Indirect tax | 04 September 2025 | Bill amending excise duties on energy approved by Parliament. Read more |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 September 2025 | Bill implementing DAC8 approved by Parliament, consultation on implementation of DAC9. Read more |
South Africa
South Africa | |||
Proposed legislation | Income tax | 26 September 2025 | Draft regulations implementing cryptoasset reporting framework (CARF) and revising common reporting standard (CRS) rules. Read more |
Tax legislation approved and regulatory update | Income tax | 24 September 2025 | Updated urban development zone (UDZ) tax incentive guide, including extension to 2030. Read more |
Administrative and case law | Tax compliance | 18 September 2025 | Foreign account tax compliance act (FATCA) and common reporting standard (CRS) third-party data bi-annual submission period. Read more |
Proposed legislation | Income tax | 05 September 2025 | Proposed changes to anti-avoidance rules for hybrid equity instruments withdrawn. Read more |
Spain
Spain | |||
Administrative and case law | Income tax | 23 September 2025 | Court Allows Expense Deductions for U.S. Residents on Spanish Rental Income. Read more |
Sweden
Sweden | |||
Administrative and case law | Indirect tax | 17 September 2025 | Canadian fund qualifies for withholding tax exemption for non-undertakings for collective investment in transferable securities (UCITS) funds (Administrative Court of Appeal decision). Read more |
Proposed legislation | Income tax | 04 September 2025 | Draft legislation exempting foreign states and municipalities from withholding tax. Read more |
Switzerland
Switzerland | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 30 September 2025 | GloBE reporting regulations adopted by Federal Council. Read more |
Administrative and case law | Various tax topics | 04 September 2025 | Consultation on introducing automatic exchange of financial account information (AEOI) agreements with eight additional jurisdictions. Read more |
Administrative and case law | Transfer Pricing | 04 September 2025 | Updated list of jurisdictions for exchange of country-by-country reports. Read more |
Tunisia
Tunisia | |||
Administrative and case law | Tax compliance | 19 September 2025 | Guidance on new mandatory electronic invoicing (e-invoicing) measures for B2B and large companies. Read more |
Administrative and case law | Income tax | 19 September 2025 | Clarification to real estate valuation procedure for preliminary tax audits. Read more |
Turkey
Turkey | |||
Tax legislation approved and regulatory update | Income tax | 23 September 2025 | Increased withholding tax rates for income from certain financial instruments. Read more |
Tax legislation approved and regulatory update | Indirect tax | 23 September 2025 | Amendments to Value Added Tax (VAT) guidance and changes to special consumption tax on petroleum products, adapted vehicles. Read more |
Proposed legislation | Various tax topics | 23 September 2025 | Draft law introducing various direct and indirect tax changes and other recent tax-related developments. Read more |
Uganda
Uganda | |||
Proposed legislation | Various tax topics | 15 September 2025 | Three-year tax exemption for certain start-up businesses. Read more |
Ukraine
Ukraine | |||
Proposed legislation | Indirect tax | 18 September 2025 | Proposed extension of Value Added Tax (VAT) exemption for electric vehicles & documentation requirements for VAT exemption for defense-related entities. Read more |
Administrative and case law | Transfer Pricing | 18 September 2025 | Constituent entities of multinational enterprise (MNE) groups parented in U.S., Canada, or Israel must file 2024 country-by-country (CbC) reports locally. Read more |
Tax legislation approved and regulatory update | Indirect tax | 05 September 2025 | Import of fiber optic drones exempt from Value Added Tax. Read more |
United Kingdom
United Kingdom | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 24 September 2025 | HM Revenue & Customs (HMRC) can retrospectively designate Pillar Two territories, qualifying top-up taxes. Read more |
Administrative and case law | Various tax topics | 18 September 2025 | Interim report on Business Rates system. Read more |
Tax legislation approved and regulatory update | Indirect tax | 15 September 2025 | New stock market for private companies with stamp duty exemptions. Read more |
Tax legislation approved and regulatory update | Indirect tax | 12 September 2025 | Penalties for late payment of Value Added Tax (VAT), other taxes. Read more |
Tax legislation approved and regulatory update | Indirect tax | 12 September 2025 | Deadline extended for final Value Added Tax (VAT) returns after cancellation of registration. Read more |
Administrative and case law | Tax compliance | 11 September 2025 | Changes to Foreign account tax compliance act (FATCA) and common reporting standard (CRS) reporting schemas. Read more |
Administrative and case law | Tax compliance | 04 September 2025 | Guidance on taxpayer declaration that tax return information is correct and complete. Read more |
Administrative and case law | Tax compliance | 04 September 2025 | Guidance on taxation of lease in-lease out (LILO) arrangements. Read more |
Administrative and case law | BEPS Pillar 2 | 04 September 2025 | Updates to new guidance manual on Pillar Two. Read more |
