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Week in Tax: January 27 � 31, 2025

Recent tax developments from around the globe for the week of January 27 � 31, 2025

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February 3, 2025

ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Week in Tax—published weekly to provide an overview of tax developments as reported in TaxNewsFlash—includes summaries of select tax-related news followed by a full list of reports (more information can be found at the links provided). Highlights include:

  • France: The tax authorities issued a new form for entities within the scope of the French Pillar Two law to fulfill reporting requirements. The form requires details about the ultimate parent entity, the entity responsible for the group information return, and the French entity handling the qualified domestic minimum top-up tax, and it also serves as a notification for country-by-country reporting, to be filed with the corporate income tax return by the specified deadline. Read TaxNewsFlash
  • Italy: The "2025 budget law" introduces various tax measures including changes to direct and indirect taxation, digital services tax, tax on crypto gains, VAT on training services, and the introduction of a reverse charge mechanism in logistics. It also includes amendments to tax credits, lower corporate income tax rates for certain investments, and specific measures related to customs, excise duties, and online gambling. Read TaxNewsFlash
  • Japan: The National Tax Agency (NTA) released the third version of guidance regarding the Japanese income inclusion rule (J-IIR). Read TaxNewsFlash

United States

  • IRS practice units: Foreign tax credit categorization of income and taxes, carryback and carryover, sourcing of income
  • Senate confirms Scott Bessent as Treasury Secretary
  • California: Property tax relief due to wildfires
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø report: Employers providing employee assistance for victims of Los Angeles wildfires
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø report: SEC comments on accounting for income taxes

Read TaxNewsFlash-United States

  • Senate Finance leaders release discussion draft of bipartisan legislation to improve IRS services

Read TaxNewsFlash-Legislative Updates

Keep up to date with tax-related developments stemming from the new administration: TaxNewsFlash-Trump Tax Agenda

Transfer Pricing

  • Bahrain: Updated domestic minimum top-up tax registration manual
  • France: Form for Pillar Two reporting requirements, country-by-country notification
  • Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
  • Japan: Updated guidance on income inclusion rule
  • Korea: Transfer of shares subject to capital gains tax at arm’s length fair market value (Tax Tribunal decision)
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø report: German case law regarding transfers of functions

Read TaxNewsFlash-Transfer Pricing

Africa

  • Kenya: Excise duty on services provided by nonresidents through digital platforms
  • Kenya: Tax amnesty program extended through June 2025
  • Liberia: Proposed 18% VAT in FY2026, proposed tax measures in 2025 budget

Read TaxNewsFlash-Africa

Americas

  • Colombia: Tax authority clarifies tax treatment for holding companies
  • Dominican Republic: Proposed changes to withholding tax in livestock sector, guidance on capital returns by trusts and transfers of real estate
  • Honduras: Average minimum wage for FY2025
  • Jamaica: Tax settlement program waives interest, penalties, and surcharges
  • Panama: New income tax return form for taxpayers in Colon Free Zone
  • Venezuela: Regulations regarding requirements for providers of computer systems used to issue invoices, other tax documents

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Senate Committee report on bill to amend fuel-efficient vehicle definition under luxury car tax, deny deductions for interest charges on tax debts
  • Bahrain: Updated domestic minimum top-up tax registration manual
  • India: Capital losses not reduced by grandfathered exempt capital gains under Mauritius treaty (Tribunal decision)
  • Indonesia: Implementation of new core tax administration system
  • Japan: Updated guidance on income inclusion rule
  • Kazakhstan: List of large taxpayers subject to monitoring
  • Kazakhstan: Pilot project for registering public procurement contracts in electronic VAT invoice system
  • Korea: Transfer of shares subject to capital gains tax at arm’s length fair market value (Tax Tribunal decision)

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Guidance on reformed investment deduction regime effective from 2025
  • Belgium: New guidelines for R&D project registration and advisory requests
  • Croatia: Tax law amendments for 2025
  • France: Form for Pillar Two reporting requirements, country-by-country notification
  • Germany: Transfer of water supply systems by municipality treated as transfer of going concern for VAT purposes; other VAT developments
  • Germany: Updated list of non-cooperative tax jurisdictions, consultation on draft amendments to Pillar Two rules, changes to transfer pricing rules, other tax developments
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø report: German case law regarding transfers of functions
  • Hungary: Mandatory e-invoicing for energy sector postponed to July 1, 2025
  • Hungary: Stricter import VAT deduction requirements effective March 2025
  • Italy: Direct and indirect tax measures in 2025 budget law
  • Malta: Property transfer tax exemptions, reduced rates extended through 2025
  • Poland: Bill including proposed VAT changes passes lower house of Parliament; excise duty regime extended to nicotine products
  • Poland: Eligible R&D costs, separate goods for VAT purposes, deemed income of board member (Supreme Administrative Court decisions)
  • Serbia: Amendments to VAT rulebook
  • Sweden: Report on government study of taxation of carried interest

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Bahamas: Updated FATCA / CRS reporting deadlines
  • Channel Islands: Updated FATCA and CRS practical guidance (Jersey)
  • France: Updated FATCA technical guidance
  • Isle of Man: Updated FATCA / CRS guidance
  • Korea: Revised CRS regulations

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Argentina: Reduced export duties
  • Hungary: Stricter import VAT deduction requirements effective March 2025
  • United States: Compliance review of economic and trade agreement with China

Read TradeNewsFlash-Trade & Customs

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø LLP does not provide legal services.

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