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 November and 30 November 2025.
International Tax Europe and Africa November 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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Austria
Austria | |||
Tax legislation approved and regulatory update | Income tax | 19 November 2025 | Amendments to the Austrian Income Tax Act to increase investment allowance. Read more. |
Proposed legislation | BEPS Pillar 2 | 11 November 2025 | Draft Tax Amendment Act 2025 includes implementation of DAC9, incorporation of OECD Pillar Two administrative guidance. Read more. |
Belgium
Belgium | |||
Proposed legislation | Various tax topics | 25 November 2025 | Tax measures in budget framework 2026-2029. Read more. |
Tax legislation approved and regulatory update | Income tax | 19 November 2025 | Withholding tax exemption for certain royalty payments. Read more. |
Administrative and case law | Various tax topics | 18 November 2025 | Extended filing deadline for domestic minimum top-up tax (DMTT) return. Read more. |
Tax legislation approved and regulatory update | Income tax | 03 November 2025 | Rents paid to foreign companies exempt from withholding tax. Read more. |
Bosnia and Herzegovina
Bosnia and Herzegovina | |||
Tax legislation approved and regulatory update | Income tax | 10 November 2025 | Tax incentives for employers to maintain employment levels. Read more. |
Botswana
Botswana | |||
Proposed legislation | Indirect tax | 12 November 2025 | Proposed amendments to Value Added Tax (VAT) law. Read more. |
Czech Republic
Czech Republic | |||
Tax legislation approved and regulatory update | Various tax topics | 12 November 2025 | Updated guidance on direct and indirect tax obligations of entities providing transport services via mobile applications. Read more. |
KPMG Publication | Various tax topics | 12 November 2025 | Summaries of recent Supreme Administrative Court (SAC) decisions. Read more. |
Proposed legislation | Various tax topics | 12 November 2025 | Draft policy statement of incoming government coalition includes mandatory transfer pricing documentation. Read more. |
European Union
European Union | |||
Administrative and case law | Indirect tax | 25 November 2025 | Court of Justice of the European Union (CJEU) referral on whether sale of real property qualifies as transfer of going concern for Value Added Tax (VAT) purposes (Netherlands). Read more. |
Administrative and case law | Various tax topics | 19 November 2025 | European Commission (EC) report on evaluation of Directive of Administrative Cooperation (DAC). Read more. |
Administrative and case law | Various tax topics | 19 November 2025 | Court of Justice of the European Union (CJEU) General Court judgment that Code of Conduct Group not covered by general presumption of confidentiality. Read more. |
Administrative and case law | Indirect tax | 17 November 2025 | Commission paper on value added tax (VAT) treatment of free-of-charge access to platform in exchange for user data. Read more. |
Tax legislation approved and regulatory update | Trade & Customs | 14 November 2025 | Agreement to repeal small consignments import relief. Read more. |
Administrative and case law | Various tax topics | 13 November 2025 | European Court Defines Boundaries Between European Union (EU) Lawmakers and National Wage Policies. Read more. |
Administrative and case law | Trade & Customs | 13 November 2025 | Court of Justice of the European Union (CJEU) judgment that export procedure for construction materials violated European Union (EU) law (Hungary). Read more. |
Administrative and case law | Indirect tax | 12 November 2025 | Court of Justice for the European Union (CJEU) Advocate General (AG) opinion on treatment of separate legal entities as single taxable person for Value Added Tax (VAT) purposes (Czech Republic). Read more. |
Administrative and case law | Indirect tax | 12 November 2025 | Court of Justice of the European Union (CJEU) judgments on denial of value added tax (VAT) deduction for nonexistent transaction, taxation of VAT refund administration services (Hungary). Read more. |
Administrative and case law | Indirect tax | 11 November 2025 | Court of Justice of the European Union (CJEU) Advocate General (AG) opinion that Value Added Tax (VAT) margin scheme applies to artwork sales by legal entities (France). Read more. |
Administrative and case law | Trade & Customs | 10 November 2025 | Court of Justice of the European Union (CJEU) referral on classification for customs purposes of acid-treated and industrial-use fish under combined nomenclature. Read more. |
Administrative and case law | BEPS Pillar 2 | 04 November 2025 | Challenge to European Union (EU) minimum tax directive on standing grounds (Court of Justice of the European Union (CJEU) judgment). Read more. |
Tax legislation approved and regulatory update | Trade & Customs | 04 November 2025 | Amendments to Carbon Border Adjustment mechanism (CBAM) regulation. Read more. |
France
France | |||
Administrative and case law | Income tax | 11 November 2025 | Foreign exchange losses related to dividends under participation exemption are fully deductible (Supreme Court decision). Read more. |
Germany
Germany | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 26 November 2025 | Amendments to Pillar Two rules passed by lower house of Parliament, draft DAC9 legislation submitted to upper house of Parliament. Read more. |
Administrative and case law | Indirect tax | 10 November 2025 | Taxpayer not required to confirm validity of Value Added Tax (VAT) identification number in advance of every transaction, other VAT developments. Read more. |
Greece
Greece | |||
Tax legislation approved and regulatory update | Various tax topics | 21 November 2025 | Value Added Tax (VAT) suspension on real estate extended to December 31, 2026. Read more. |
Administrative and case law | Various tax topics | 17 November 2025 | Guidance on application of digital transaction duty (DTD). Read more. |
Guernsey
Guernsey | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 November 2025 | Initial Pillar Two guidance. Read more. |
Ireland
Ireland | |||
Administrative and case law | Indirect tax | 20 November 2025 | Guidance on application of value added tax (VAT) grouping rules. Read more. |
Italy
Italy | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 20 November 2025 | Filing and payment obligations for Pillar Two top-up tax. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 05 November 2025 | Global anti-base erosion (GloBE) information return (GIR) and filing instructions. Read more. |
Liechtenstein
Liechtenstein | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 November 2025 | Additional Pillar Two registration requirement adopted. Read more. |
Luxembourg
Luxembourg | |||
Administrative and case law | Indirect tax | 18 November 2025 | Guidance clarifies Value Added Tax (VAT) treatment of company cars. Read more. |
Administrative and case law | Various tax topics | 14 November 2025 | Updated common reporting standard (CRS) frequently asked questions (FAQs). Read more. |
Administrative and case law | Tax compliance | 04 November 2025 | Updated common reporting standard (CRS) guidance. Read more. |
Malta
Malta | |||
Administrative and case law | Various tax topics | 18 November 2025 | Guidance on automatic exchange of information (AEOI). Read more. |
Mauritania
Mauritania | |||
Tax legislation approved and regulatory update | Various tax topics | 19 November 2025 | Tax provisions in Supplementary Finance Law for 2025. Read more. |
Moldova
Moldova | |||
Administrative and case law | Indirect tax | 10 November 2025 | Value Added Tax (VAT) liability under long-term contracts arises at date of invoice. Read more. |
Nigeria
Nigeria | |||
Tax legislation approved and regulatory update | Various tax topics | 05 November 2025 | Transition to new economic development tax incentive scheme. Read more. |
North Macedonia
North Macedonia | |||
Proposed legislation | Indirect tax | 10 November 2025 | Pilot phase of electronic invoicing (e-invoicing) to begin January 1, 2026. Read more. |
OECD
OECD | |||
Administrative and case law | BEPS Pillar 2 | 26 November 2025 | Report to G20 leaders on international tax cooperation, G20 leaders’ declaration on Pillar Two. Read more. |
Administrative and case law | Various tax topics | 19 November 2025 | Updates to Fixed Place of Business in Remote Work. Read more. |
Administrative and case law | Income tax | 19 November 2025 | 2025 update to Organisation for Economic Co-operation and Development (OECD) Model Tax Convention. Read more. |
Administrative and case law | BEPS Pillar 2 | 19 November 2025 | Updated list of signatories to the GloBE Information Return (GIR) Multilateral Competent Authority Agreement (MCAA) Read more. |
Poland
Poland | |||
Administrative and case law | Indirect tax | 18 November 2025 | Continuity of business as condition for Value Added Tax (VAT) exemption (Supreme Administrative Court decision). Read more. |
Administrative and case law | Various tax topics | 04 November 2025 | Summaries of recent Supreme Administrative Court decisions. Read more. |
KPMG Publication | Various tax topics | 04 November 2025 | Proposed increased Value Added Tax (VAT) rate on non-alcoholic and energy drinks, reduced tax on extraction of certain minerals. Read more. |
Portugal
Portugal | |||
Tax legislation approved and regulatory update | Income tax | 19 November 2025 | Reduction in corporate income tax rates from 20% to 17%. Read more. |
Romania
Romania | |||
Tax legislation approved and regulatory update | Indirect tax | 24 November 2025 | Proposed logistics tax on certain goods from outside European Union. Read more. |
Proposed legislation | Various tax topics | 11 November 2025 | Draft laws propose direct and indirect tax changes. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 11 November 2025 | Amendments to Pillar Two rules. Read more. |
Serbia
Serbia | |||
Proposed legislation | Various tax topics | 05 November 2025 | Public consultation on draft law on fees for use of public resources. Read more. |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | Various tax topics | 21 November 2025 | New Tax Provisions Will Take Effect in 2026. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 13 November 2025 | Expanded scope of binding tax opinions on income tax, value added tax, and financial transaction tax. Read more. |
Slovenia
Slovenia | |||
Tax legislation approved and regulatory update | Income tax | 19 November 2025 | Updated tax rules for Derivative Financial Instruments and Alternative Investment Funds. Read more. |
South Africa
South Africa | |||
Proposed legislation | Income tax | 20 November 2025 | Proposed amendments to application of “conduit principle” in relation to trust distributions. Read more. |
Tax legislation approved and regulatory update | Income tax | 10 November 2025 | Compliance requirements for income transfers by residents to nonresidents. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 10 November 2025 | Tax incentive for energy-efficiency savings extended through 2030. Read more. |
Administrative and case law | Income tax | 07 November 2025 | Tax implications of introduction of South African Rand Overnight Index Average Rate (ZARONIA) as key reference interest rate. Read more. |
Administrative and case law | Various tax topics | 06 November 2025 | Removal from Financial Action Task Force (FATF) “grey list”. Read more. |
Proposed legislation | Tax compliance | 03 November 2025 | Draft business requirement specifications for FATCA, Common Reporting Standard (CRS), and cryptoasset reporting framework. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 11 November 2025 | Three new Pillar Two forms approved. Read more. |
Administrative and case law | Income tax | 04 November 2025 | Beneficial ownership requirement inapplicable to domestic interest exemption (court decision). Read more. |
Switzerland
Switzerland | |||
Administrative and case law | Various tax topics | 14 November 2025 | Postponement of review of draft law introducing cryptoasset reporting framework (CARF). Read more. |
Proposed legislation | Various tax topics | 12 November 2025 | Consultation on protocol amending automatic exchange of financial account information (AEOI) agreement with European Union (EU). Read more. |
Administrative and case law | BEPS Pillar 2 | 11 November 2025 | Application of Pillar Two rules to hybrid arbitrage arrangements under Country-by-Country (CbC) reporting safe harbor. Read more. |
Turkey
Turkey | |||
Tax legislation approved and regulatory update | Indirect tax | 20 November 2025 | Revised special consumption tax (SCT) rates for passenger cars and light vehicles. Read more. |
Tax legislation approved and regulatory update | Income tax | 20 November 2025 | New law includes limit on duration of corporate income tax incentives, restrictions on stamp tax exemptions for Research & Development personnel. Read more. |
Administrative and case law | Various tax topics | 20 November 2025 | Guidance on direct and indirect taxation of sports sponsorship expenses, certain stamp duty refund claims require litigation. Read more. |
United Kingdom
United Kingdom | |||
Tax legislation approved and regulatory update | Tax compliance | 25 November 2025 | Guidance on cryptoasset reporting framework (CARF). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 19 November 2025 | Updated international exchange of information manual. Read more. |
Administrative and case law | Transfer pricing | 13 November 2025 | HM Revenue & Customs (HMRC)'s transfer pricing settlement policy. Read more. |
Administrative and case law | Tax compliance | 04 November 2025 | Updated guidance on automatic exchange of information (AEOI) reporting and account holders compliance. Read more. |
