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ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Week in Tax: April 7 â€� 11, 2025

Recent tax developments from around the globe for the week of April 7 � 11, 2025

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April 14, 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).

  • United States: Congress passed a budget resolution for FY 2025, setting budgetary levels through FY 2034 and authorizing work on an FY 2025 reconciliation bill to achieve at least $1.5 trillion in mandatory savings and up to $4.5 trillion in net tax cuts over 10 years. The resolution, which increases the statutory debt limit by $4 trillion, allows the House and Senate to use the reconciliation process for filibuster-proof passage of tax legislation, with the next step being the drafting and passing of identical reconciliation bills in both chambers to be sent to the president for signature. Read TaxNewsFlash
  • United States: Executive Order 14547 directs the repeal of regulations deemed unlawful without notice-and-comment proceedings if a “good causeâ€� exception is satisfied. Read TaxNewsFlash
  • OECD: A statement following the Inclusive Framework meeting on BEPS indicated agreement to continue discussions on Pillar One and Pillar Two. In addition, despite the Trump Administration's recent withdrawal of support for the OECD Global Tax Deal, the United States continued to participate in negotiations. Read TaxNewsFlash
  • EU: The Advocate General of the CJEU issued a nonbinding opinion suggesting that electronic marketplaces acted as undisclosed agents before 2015, thereby creating a legal fiction of two transactions for value added tax (VAT) purposes. If adopted, this interpretation could extend the application of the undisclosed agent principle to electronically supplied services and other transactions facilitated by marketplaces prior to 2015, with implications for VAT liability and place of supply rules. Read TaxNewsFlash

United States

  • Executive order directs the repeal of “unlawful regulationsâ€� without notice and comment
  • IRS correction: Extended filing deadline for Forms 1042-S is April 17, 2025
  • IRS practice units: Deductions and credits on Form 1120-F delinquent returns; deductions for nonresident alien individuals; branch-level interest tax concepts
  • Notice 2025-24: Relief from penalties for failure to timely file disclosure statements for micro-captive reportable transactions
  • President Trump signs into law joint resolution overturning digital asset information reporting regulations
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Does transfer pricing have a Loper Bright problem?
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Tax treatment of futures contracts
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Unraveling timing and character of revolver net-back payments
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Update on the IRS’s focus on high-income and high-wealth individuals

Read TaxNewsFlash-United States


Legislative Updates

  • Congress passes 2025 budget resolution allowing up to $4.5 trillion in net tax cuts

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Belgium: Tax return under Pillar Two rules
  • EU: Transfer pricing adjustments are subject to VAT (CJEU Advocate General opinion)
  • OECD: Statement following meeting of Inclusive Framework on BEPS
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Does U.S. transfer pricing have a Loper Bright problem?

Read TaxNewsFlash-Transfer Pricing

Africa

  • Kenya: VAT is payable on commercial property sales (Court of Appeal decision)
  • Rwanda: Proposed digital services tax (DST) introduced

Read TaxNewsFlash-Africa

Americas

  • Brazil: New guidelines for e-invoicing layouts due to tax reform
  • Brazil: Proposed contribution for digital content that targets children
  • Canada: No changes to income tax rates in 2025 budget (Newfoundland and Labrador)

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Further entity disclosures required under “Consolidated Entity Disclosure Statementsâ€�
  • Australia: R&D tax incentive registration deadline is April 30
  • Bahrain: Action plan approved for 2025-2026 budget, corporate tax to be introduced
  • Kazakhstan: Expanded list of vehicles and agricultural machinery components exempt from VAT
  • New Zealand: New tax governance guidance

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Tax return under Pillar Two rules
  • Cyprus: Guidance on VAT treatment of unredeemed expired vouchers
  • EU: Electronic marketplaces qualify as undisclosed agents pre-2015 amendments (CJEU Advocate General opinion)
  • EU: Transfer pricing adjustments are subject to VAT (CJEU Advocate General opinion)
  • Lithuania: Application of participation exemption, abuse provision (CJEU judgment)
  • Poland: New rules for keeping books of account
  • Poland: Opinion on amendments to R&D tax relief
  • Poland: Sale of assets covered by statutory joint property ownership by spouses is subject to VAT (CJEU judgment)
  • Romania: Changes to construction tax
  • Ukraine: Proposed legislation for digital platform reporting and withholding tax requirements

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • British Virgin Islands: Deployment of payment module and new CRS form on BVIFARS portal
  • Singapore: Updated record level error codes for CRS
  • United States: Extended filing deadline for Forms 1042-S is April 17, 2025
  • Uruguay: Updated guidance regarding submission of CRS reports

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Canada requests WTO dispute consultations regarding U.S. duties on automobiles and auto parts
  • China requests WTO dispute consultations regarding U.S. reciprocal tariffs
  • EU member states approve trade countermeasures against United States
  • India: Revised draft export and import regulations
  • United States increases tariffs on Chinese imports
  • United States modifies reciprocal tariff rates in response to trading partner retaliation and alignment
  • U.S. BIS updates “boycott requester listâ€�
  • U.S. CBP updates guidance on reciprocal tariffs
  • White House executive summary of report on “America First Trade Policyâ€�

Read TradeNewsFlash-Trade & Customs

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