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 April and 30 April 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

Various tax topics

22 April 2025

Limitation on application of prohibition on deducting intragroup interest and license fees (Federal Finance Court decisions). Read more.

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Belgium

 

Belgium

Proposed legislation

Income tax

30 April 2025

Proposed capital gains tax on financial assets. Read more.

Tax legislation approved and regulatory update

Various tax topics

17 April 2025

Draft program law includes first series of tax measures included in coalition agreement. Read more.

Tax legislation approved and regulatory update

Transfer pricing

11 April 2025

Tax return under Pillar Two rules. Read more.

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Bosnia and Herzegovina

 

Bosnia and Herzegovina

Proposed legislation

Income tax

16 April 2025

Proposed forgiveness of interest on tax debts (Republic of Srpska). Read more.

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Bulgaria

 

Bulgaria

Tax legislation approved and regulatory update

BEPS Pillar 2

01 April 2025

Amendments to Pillar Two law enacted. Read more.

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Cyprus

 

Cyprus

Tax legislation approved and regulatory update

Income tax

29 April 2025

“Defensive” tax measures for payments to EU non-cooperative and low-tax jurisdictions. Read more.

Tax legislation approved and regulatory update

Indirect tax

11 April 2025

Guidance on Value Added Tax (VAT) treatment of unredeemed expired vouchers. Read more.

Tax legislation approved and regulatory update

Income tax

04 April 2025

Extended deadline for non-taxation election on property leasing. Read more.

Tax legislation approved and regulatory update

Various tax topics

03 April 2025

Tax card for 2025. Read more.

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Czech Republic

 

Czech Republic

Tax legislation approved and regulatory update

Income tax

25 April 2025

Single Monthly Employer Reporting and Related Changes to Income Tax. Read more.

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Denmark

 

Denmark

Tax legislation approved and regulatory update

Various tax topics

16 April 2025

Proposed legislation to implement cryptoasset reporting (DAC8). Read more.

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Djibouti

 

Djibouti

Tax legislation approved and regulatory update

Various tax topics

16 April 2025

Tax measures in Finance Law 2025. Read more.

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European Union

 

European Union

Tax legislation approved and regulatory update

Others

30 April 2025

Targeted consultation on barriers to EU capital markets integration. Read more.

Tax legislation approved and regulatory update

Tax compliance

30 April 2025

Member states express concerns regarding Clean Industry State Aid Framework proposal. Read more.

Tax legislation approved and regulatory update

Trade & Customs

15 April 2025

European Union (EU) pauses countermeasures against US tariffs to allow for negotiations. Read more.

Tax legislation approved and regulatory update

Tax compliance

15 April 2025

European Commission approves Finnish state aid tax credit scheme to support green transition. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

14 April 2025

Council adopts DAC9. Read more.

Tax legislation approved and regulatory update

Indirect tax

10 April 2025

Electronic marketplaces qualify as undisclosed agents pre-2015 amendments (CJEU Advocate General opinion). Read more.

Tax legislation approved and regulatory update

Trade & Customs

09 April 2025

EU member states approve trade countermeasures against United States. Read more.

Administrative and case law

Transfer pricing

07 April 2025

Transfer pricing adjustments are subject to VAT (CJEU Advocate General opinion). Read more.

Proposed legislation

Treaties

01 April 2025

Tax aspects of European Commission communication on savings and investments union. Read more.

Proposed legislation

Income tax

01 April 2025

Commissioner outlines EC tax priorities at 2025 EU Tax Symposium. Rea

d more.

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Finland

 

Finland

Tax legislation approved and regulatory update

Tax compliance

30 April 2025

Consultation on amendments to interest deduction limitation rules for critical entities financing long-term infrastructure projects. Read more.

Tax legislation approved and regulatory update

Tax compliance

30 April 2025

Enhancements to check routines for common reporting standard (CRS) / DAC2. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

01 April 2025

Guidance on Pillar Two global minimum tax. Read more.

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France

 

France

Tax legislation approved and regulatory update

Indirect tax

17 April 2025

Value Added Tax (VAT) exemption threshold reduction for small businesses postponed until June 1, 2025. Read more.

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Germany

 

Germany

Tax legislation approved and regulatory update

Indirect tax

30 April 2025

Value Added Tax (VAT) reforms included in coalition agreement, other VAT developments. Read more.

Administrative and case law

Income tax

25 April 2025

Recent court decisions relating to taxation of real estate. Read more.

Tax legislation approved and regulatory update

Transfer pricing

21 April 2025

Amended list of jurisdictions exchanging country-by-country (CbC) reports. Read more.

Tax legislation approved and regulatory update

Various tax topics

18 April 2025

Updated common reporting standard (CRS) guidance. Read more.

Tax legislation approved and regulatory update

Transfer pricing

15 April 2025

Guidance on the treatment of tax transparent entities for Country-by-Country Reporting and Pillar Two purposes. Read more.

Tax legislation approved and regulatory update

Various tax topics

15 April 2025

Coalition agreement includes plans for comprehensive tax reforms. Read more.

Tax legislation approved and regulatory update

Income tax

04 April 2025

Increased tax audit scrutiny on intra-group data centers. Read more.

Tax legislation approved and regulatory update

Income tax

01 April 2025

Final guidance on interest deduction limitation rules. Read more.

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Ghana

 

Ghana

Tax legislation approved and regulatory update

Various tax topics

03 April 2025

Tax measures in 2025 budget. Read more.

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Gibraltar

 

Gibraltar

Proposed legislation

Income tax

30 April 2025

Proposed changes to income tax anti-avoidance rules. Read more.

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Greece

 

Greece

Tax legislation approved and regulatory update

Income tax

28 April 2025

New law introduces tax incentives for investors and corporate transformations. Read more.

Tax legislation approved and regulatory update

Indirect tax

16 April 2025

Value Added Tax (VAT) exemption process for supply and intra-Community acquisition of certain goods. Read more.

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Ireland

 

Ireland

Tax legislation approved and regulatory update

Various tax topics

15 April 2025

Public Consultation on the research and development (R&D) tax credit and on options to support innovation. Read more.

Tax legislation approved and regulatory update

Various tax topics

15 April 2025

European Commission approves modification and extension of film tax relief scheme Read more.

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Italy

 

Italy

Tax legislation approved and regulatory update

Indirect tax

22 April 2025

Guidance for fiscal representatives on eligibility criteria and submission of guarantees. Read more.

Tax legislation approved and regulatory update

Indirect tax

16 April 2025

Implementation of obligation for non-European Union (EU) companies operating in Italy through a fiscal representative to submit guarantee. Read more.

Administrative and case law

Various tax topics

01 April 2025

Imposition of IRAP on dividends may be inconsistent with Parent-Subsidiary Directive (PSD) depending on nature of tax (CJEU Advocate General opinion). Read more.

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Kenya

 

Kenya

Administrative and case law

Indirect tax

09 April 2025

VAT is payable on commercial property sales (Court of Appeal decision). Read more.

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Libya

 

Libya

Tax legislation approved and regulatory update

Tax compliance

23 April 2025

Statute of limitations on tax audits and collections repealed. Read more.

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Liechtenstein

 

Liechtenstein

Tax legislation approved and regulatory update

Transfer pricing

01 April 2025

Liechtenstein Draft amendments to minimum tax rules (under Pillar Two) published. Read more.

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Lithuania

 

Lithuania

Proposed legislation

Income tax

30 April 2025

Tax proposals include corporate tax increase, tax incentives for asset acquisitions and small enterprises. Read more.

Administrative and case law

Others

08 April 2025

Application of participation exemption, abuse provision (CJEU judgment). Read more.

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Malta

 

Malta

Tax legislation approved and regulatory update

Tax compliance

24 April 2025

Large taxpayer office established. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

22 April 2025

Elective tax for Pillar Two in-scope companies to be introduced. Read more.

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Moldova

 

Moldova

Proposed legislation

Indirect tax

16 April 2025

Consultations on implementation of various European Union (EU) directives. Read more.

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Namibia

 

Namibia

Proposed legislation

Various tax topics

01 April 2025

Tax proposals in 2025/2026 budget. Read more.

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Netherlands

 

Netherlands

Tax legislation approved and regulatory update

Income tax

25 April 2025

Tax measures in 2025 Spring Memorandum sent to Parliament. Read more.

Administrative and case law

Income tax

01 April 2025

Capital loss upon liquidation of subsidiary allowed (Supreme Court decision). Read more.

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Nigeria

 

Nigeria

Tax legislation approved and regulatory update

Others

15 April 2025

New online pension contribution system. Read more.

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OECD

 

OECD

Tax legislation approved and regulatory update

BEPS Pillar 2

15 April 2025

Updated outcome of Pillar Two transitional peer review process. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

11 April 2025

Statement following meeting of Inclusive Framework on Base Erosion and Profit Shifting (BEPS). Read more.

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Poland

 

Poland

Trade and customs

Income tax

30 April 2025

Clearance opinion approving group restructuring. Read more.

Administrative and case law

Income tax

29 April 2025

Liability of board member for company’s tax debts (CJEU judgment). Read more.

Administrative and case law

Indirect tax

29 April 2025

Summaries of recent Supreme Administrative Court decisions. Read more.

Administrative and case law

Various tax topics

29 April 2025

Property tax exemption does not appear to constitute illegal State aid (Court of Justice of the European Union (CJEU) judgment). Read more.

Administrative and case law

Income tax

29 April 2025

Liability of board member for company’s tax debts (Court of Justice of the European Union (CJEU) judgment). Read more.

Proposed legislation

Indirect tax

16 April 2025

Proposed postponement of certain elements of mandatory national electronic invoicing system (KSeF). Read more.

KPMG publication

Various tax topics

16 April 2025

Deductibility of taxpayer’s own loans contributed to company, limitations on real property depreciation (court decisions). Read more.

Proposed legislation

BEPS Pillar 2

16 April 2025

Proposed legislation amending Pillar Two rules. Read more.

Tax legislation approved and regulatory update

Indirect tax

10 April 2025

Sale of assets covered by statutory joint property ownership by spouses is subject to Value Added Tax (VAT) (CJEU judgment). Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

10 April 2025

Opinion on amendments to R&D tax relief. Read more.

Tax legislation approved and regulatory update

Indirect tax

10 April 2025

Sale of assets covered by statutory joint property ownership by spouses is subject to Value Added Tax (CJEU judgment). Read more.

Tax legislation approved and regulatory update

Tax compliance

10 April 2025

New rules for keeping books of account. Read more.

Administrative and case law

Various tax topics

04 April 2025

Summaries of recent court decisions. Read more.

Tax legislation approved and regulatory update

Various tax topics

04 April 2025

Consultation on draft regulation on maintaining tax revenue and expense ledgers. Read more.

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Romania

 

Romania

Tax legislation approved and regulatory update

Indirect tax

16 April 2025

Guidance on Value Added Tax (VAT) registration and use of e-invoicing in B2G transactions. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

09 April 2025

Changes to construction tax. Read more.

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Rwanda

 

Rwanda

Proposed legislation

 

Income tax

 

9 April 2025

Proposed digital services tax (DST) introduced. Read more.

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Slovakia

 

Slovakia

Tax legislation approved and regulatory update

Indirect tax

 

2 April 2025

Input Value Added Tax (VAT) deduction limited to 50 percent on purchase of motor vehicles and motorcycles. Read more.

 

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South Africa

 

South Africa

Tax legislation approved and regulatory update

Others

30 April 2025

Change in SARSQA Connect Direct Public Certificate. Read more.

Proposed legislation

Indirect tax

24 April 2025

Withdrawal of proposed Value Added Tax (VAT) increase. Read more.

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Spain

 

Spain

Tax legislation approved and regulatory update

Various tax topics

14 April 2025

Updated tax reporting requirements for financial sector. Read more.

Tax legislation approved and regulatory update

Indirect tax

14 April 2025

Extended deadline for adapting e-invoicing software, new exemption in certain cases of invoicing by recipient or third party. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

2 April 2025

Regulations under Pillar Two global minimum tax law. Read more.

Tax legislation approved and regulatory update

Indirect tax

2 April 2025

Amendments to real estate transfer tax and stamp duty (Catalonia). Read more.

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Sweden

 

Sweden

Tax legislation approved and regulatory update

BEPS Pillar 2

20 March 2025

Sweden Public consultation on additional amendments to Swedish Top-up Tax Act. Read more.

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Switzerland

 

Switzerland

Tax legislation approved and regulatory update

BEPS Pillar 2

18 March 2025

Switzerland - Guidance issued on the treatment of permanent establishments for Swiss minimum tax purposes. Read more.

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Tunisia

 

Tunisia

Tax legislation approved and regulatory update

Various tax topics

15 April 2025

Tunisia introduces corporate tax reforms under the 2025 Finance Law. Read more.

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Uganda

 

Uganda

Proposed legislation

Various tax topics

23 April 2025

Proposed changes to tax laws, including replacement of 5% Digital Services Tax (DST) with 15% withholding tax. Read more.

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Ukraine

 

Ukraine

Proposed legislation

Income tax

10 April 2025

Proposed legislation for digital platform reporting and withholding tax requirements. Read more.

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United Kingdom

 

United Kingdom

Tax legislation approved and regulatory update

Various tax topics

17 April 2025

Guidance removing blanket application of anti-abuse rule to capital contributions resulting in LLP member qualifying as genuine partner. Read more.

Tax compliance

Income tax

4 April 2025

6 July Employee Share Plan Reporting Deadline. Read more.

Administrative and case law

Various tax topics

3 April 2025

Costs for preliminary windfarm studies qualified as capital expenditures (Court of Appeal decision). Read more.

Proposed legislation

Various tax topics

3 April 2025

Consultation on proposed improvements to advance tax clearance process for research and development (R&D) claims following Spring Statement. Read more.

Tax legislation approved and regulatory update

Income tax

3 April 2025

Consultation on new advance tax clearance service for large innovative investment projects following Spring Statement. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

3 April 2025

Lists of jurisdictions with qualifying income inclusion rules and domestic top-up taxes under Pillar Two rules. Read more.

Tax legislation approved and regulatory update

BEPS Pillar 2

1 April 2025

2025 Finance Act enacted, includes changes to UK Pillar Two rules. Read more.

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United Nation

 

United Nation

KPMG publication

Transfer pricing

1 April 2025

KPMG report: Overview of topics and workstreams discussed at recent meeting of UN Tax Committee. Read more.

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