International Tax Europe and Africa January 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 January and 31 January 2025.
Netherlands | |
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 | |||
Tax legislation approved and regulatory update | Income tax | 31 January 2025 | New guidelines for research and development project registration and advisory requests. Read more. |
Tax legislation approved and regulatory update | Income tax | 28 January 2025 | Guidance on reformed investment deduction regime effective from 2025. Read more. |
Bulgaria
Bulgaria | |||
Proposed legislation | Indirect tax | 06 January 2025 | Proposed mandatory use of SAF-T report. Read more. |
Croatia
Croatia | |||
Tax legislation approved and regulatory update | Various tax topics | 28 January 2025 | Tax law amendments for 2025. Read more. |
Cyprus
Cyprus | ||||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 21 January 2025 | Implementation of Pillar Two global minimum tax rules and public country-by-country reporting. Read more. |
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Czech Republic
Czech Republic | |||
Tax legislation approved and regulatory update | Indirect tax | 08 January 2025 | Changes in taxation of immovable property in 2025. Read more. |
Denmark
Denmark | |||
Administrative and case law | Transfer pricing | 09 January 2025 | Taxpayer prepared adequate transfer pricing documentation and related party payments were arm’s length (Supreme Court decision). Read more. |
Egypt
Egypt | |||
Tax legislation approved and regulatory update | Indirect tax | 14 January 2025 | New taxpayers required to comply with the mandate to issue electronic receipts for Business to Customers transactions. Read more. |
European Union
European Union | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 21 January 2025 | Tax priorities of Polish Presidency of the Council. Read more. |
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France
France | |||
Tax legislation approved and regulatory update | Tax compliance | 28 January 2025 | Updated FATCA technical guidance. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 27 January 2025 | Form for Pillar Two reporting requirements, country-by-country notification. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 24 January 2025 | Updated common reporting standards technical guidance. Read more. |
Germany
Germany | |||
Tax legislation approved and regulatory update | Indirect tax | 31 January 2025 | Transfer of water supply systems by municipality treated as transfer of going concern for Value added tax purposes. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 30 January 2025 | Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 28 January 2025 | KPMG report: German case law regarding transfers of functions. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 30 January 2025 | Federal Ministry of Finance: Intra-Group Financing – Administrative Principles on Transfer Pricing 2024. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 30 January 2025 | Federal Ministry of Finance: Guidance on the German controlled foreign companies Rules Old Version – Motive Test. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 30 January 2025 | Federal Ministry of Finance: Guidance on the Application of the Anti-Hybrids Rules. Read more. |
Administrative and case law | Transfer pricing | 30 January 2025 | Lower Tax Court of Düsseldorf (1 K 2666/19 F): German controlled foreign companies Rules – Functional Approach / Violation of the Free Movement of Capital in Third-Country Cases. Read more. |
Proposed legislation | Transfer pricing | 30 January 2025 | Revised Draft Law Proposing Amendments to Minimum Tax Act. Read more. |
Proposed legislation | Income tax | 30 January 2025 | Government Draft Bill for a Second Future Financing Act. Read more. |
Tax legislation approved and regulatory update | Income tax | 30 January 2025 | Tax Development Act Promulgated. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 30 January 2025 | Tax Haven Defence Regulation 2024 Promulgated. Read more. |
Greece
Greece | |||
Tax legislation approved and regulatory update | Treaties | 15 January 2025 | Income tax treaty with Japan in force, list of non-cooperative countries for FY2023. Read more. |
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Hungary
Hungary | |||
Tax legislation approved and regulatory update | Indirect tax | 29 January 2025 | Mandatory e-invoicing for energy sector postponed to July 1, 2025. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 29 January 2025 | Stricter import value added tax deduction requirements effective March 2025. Read more. |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 09 January 2025 | Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities. Read more. |
Isle of Man
Tax legislation approved and regulatory update | Tax compliance | 31 January 2025 | Updated FATCA / common reporting standards guidance. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 15 January 2025 | Guidance for Automatic Exchange Of Information onsite visits. Read more. |
Italy
Italy | |||
Tax legislation approved and regulatory update | Various tax topics | 30 January 2025 | Direct and indirect tax measures in 2025 budget law. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 22 January 2025 | Budget law introduces new value added tax reverse charge mechanism for logistics sector. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 10 January 2025 | Budget law expands scope of digital service tax. Read more. |
Jersey
Jersey | |||
Tax legislation approved and regulatory update | Tax compliance | 28 January 2025 | Updated FATCA and common reporting standards practical guidance (Jersey). Read more. |
Kenya
Kenya | |||
Tax legislation approved and regulatory update | Indirect tax | 29 January 2025 | Excise duty on services provided by nonresidents through digital platforms. Read more. |
Tax legislation approved and regulatory update | Income tax | 27 January 2025 | Tax amnesty program extended through June 2025. Read more. |
Liberia
Liberia | |||
Proposed legislation | Indirect tax | 31 January 2025 | Proposed 18% value added tax in FY2026, proposed tax measures in 2025 budget. Read more. |
Luxembourg
Luxembourg | |||
Tax legislation approved and regulatory update | Income tax | 21 January 2025 | Updated guidance on certificates of residence for collective investment funds. Read more. |
Malta
Malta | |||
Tax legislation approved and regulatory update | Indirect tax | 31 January 2025 | Property transfer tax exemptions, reduced rates extended through 2025. Read more. |
Moldova
Moldova | |||
Tax legislation approved and regulatory update | Income tax | 07 January 2025 | New tax return form for small and medium-sized enterprises. Read more. |
Netherlands
Netherlands | |||
Tax legislation approved and regulatory update | Indirect tax | 21 January 2025 | KPMG report: Global developments in Environment, Social, and Governance (ESG)-related taxes, incentives, and grants (ESG tax tracker, updated January 2025). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 08 January 2025 | Shipping and offshore tax update (January 2025). Read more. |
North Macedonia
Tax legislation approved and regulatory update | BEPS Pillar 2 | 09 January 2025 | Parliament adopts law implementing Pillar Two global minimum tax rules. Read more. |
Norway
Norway | |||
Tax legislation approved and regulatory update | Income tax | 31 January 2025 | Approval for National Budget 2025. Read more. |
OCED
OECD | |||
Tax legislation approved and regulatory update | Transfer pricing | 17 January 2025 | KPMG report: Inclusive Framework Administrative Guidance on limitation of the use of deferred tax assets under transitional rules (Article 9.1). Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 17 January 2025 | KPMG report: Inclusive Framework guidance on application of GloBE rules. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 15 January 2025 | Inclusive Framework on BEPS releases updates to global minimum tax administration. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 1 | 13 January 2025 | Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One. Read more. |
Poland
Poland | |||
Tax legislation approved and regulatory update | Various tax topics | 31 January 2025 | Eligible research and development costs, separate goods for value added tax purposes, deemed income of board member. Read more. |
Proposed legislation | Indirect tax | 31 January 2025 | Bill including proposed value added tax changes passes lower house of Parliament, excise duty regime extended to nicotine products. Read more. |
Administrative and case law | Income tax | 23 January 2025 | Deductibility of various expenses (Supreme Administrative Court decisions). Read more. |
Tax legislation approved and regulatory update | Indirect tax | 23 January 2025 | European Union Council approves extension of split payment mechanism. Read more. |
Administrative and case law | Indirect tax | 16 January 2025 | Summaries of recent Supreme Administrative Court decisions. Read more. |
Administrative and case law | Income tax | 09 January 2025 | Contractual penalty for failure to provide services on time not excluded from tax-deductible costs. Read more. |
Tax legislation approved and regulatory update | Income tax | 09 January 2025 | Updated list of countries and territories applying harmful tax competition. Read more. |
Portugal
Portugal | |||
Administrative and case law | Indirect tax | 07 January 2025 | Charges on telecom operators held unconstitutional (Constitutional Court decision). Read more. |
Romania
Romania | |||
Tax legislation approved and regulatory update | Indirect tax | 23 January 2025 | Form for tax registration of nonresident payment service providers. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 21 January 2025 | Clarifications on reporting form for public country-by-country disclosures. Read more. |
Serbia
Serbia | |||
Tax legislation approved and regulatory update | Indirect tax | 29 January 2025 | Amendments to value added tax rulebook. Read more. |
Slovakia
Slovakia | |||
Proposed legislation | Tax compliance | 23 January 2025 | Draft legislation implementing directive on tax transparency rules for cryptoasset service providers. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 23 January 2025 | Guide on new Value Added Tax rates for energy supplies effective January 1, 2025. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 23 January 2025 | Legislation amending motor vehicle tax rates approved by Parliament. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 06 January 2025 | Proposed mandatory e-invoicing from January 1, 2027. Read more. |
Slovenia
Slovenia | |||
Tax legislation approved and regulatory update | Transfer pricing | 21 January 2025 | Implementation of public country-by-country reporting. Read more. |
Tax legislation approved and regulatory update | Income tax | January 07, 2025 | Amendments to tax procedure law, amendments and clarifications to corporate income tax law. Read more. |
Proposed legislation | Indirect tax | January 07, 2025 | Proposed amendments to excise duties. Read more. |
South Africa
South Africa | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | January 22, 2025 | Legislation implementing Pillar Two global minimum tax rules enacted. Read more. |
Administrative and case law | Income tax | January 17, 2025 | Meaning of “bulk” for royalty tax purposes (High Court decision). Read more. |
South Sudan
South Sudan | |||
Tax legislation approved and regulatory update | Various tax topics | 22 January 2025 | Tax measures in Financial Act 2024 / 2025. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | Indirect tax | January 22, 2025 | Filings for special taxes due in early 2025. Read more. |
Administrative and case law | Income tax | January 21, 2025 | Dividend withholding tax in breach of European Union law (CJEU judgment). Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | January 15, 2025 | Law implementing Pillar Two global minimum tax approved. Read more. |
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Sweden
Sweden | |||
Tax legislation approved and regulatory update | Income tax | January 29, 2025 | Report on government study of taxation of carried interest. Read more. |
Proposed legislation | Income tax | January 16, 2025 | Proposed changes to Research and development incentive rules. Read more. |
United Kingdom
United Kingdom | |||
Administrative and case law | Income tax | January 22, 2025 | Costs incurred in constructing quay wall eligible for plant and machinery allowances, settlement payments to regulator not treated as non-deductible penalties (court decisions) . Read more. |
Tax legislation approved and regulatory update | Income tax | January 09, 2025 | Capital gains tax rate changes in 2024 Autumn Budget accompanied by anti-forestalling measures. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | January 06, 2025 | KPMG article: Examination of UK’s “one-way street” transfer pricing rule. Read more. |
