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ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Week in Tax: April 14 â€� 18, 2025

Recent tax developments from around the globe for the week ofÌýApril 14 â€� 18, 2025

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April 21, 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: Notice 2025-23 announces plans to propose removing partnership basis shifting transactions of interest (TOI) regulations, offering immediate relief from specific penalties for participants and material advisors involved in these transactions. The notice also withdraws Notice 2024-54 and allows reliance on Notice 2025-23 until the notice of proposed rulemaking is finalized. Read TaxNewsFlash
  • EU: The Council of the European Union has adopted a further amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9) to streamline filing obligations for multinational enterprise groups by introducing a centralized framework for exchanging tax information, simplifying compliance under the Pillar Two Directive. Member states must implement DAC9 by December 31, 2025, with MNEs filing their first top-up tax information return by June 30, 2026, and tax authorities exchanging this information by December 31, 2026. Read TaxNewsFlash
  • EU: The European Union has paused its countermeasures on U.S. trade tariffs for 90 days to facilitate negotiations following the U.S. decision to delay its tariffs. This suspension, effective until July 14, 2025, responds to U.S. tariffs imposed on steel, aluminum, and derivative products. Read TradeNewsFlash
  • Germany: The German coalition agreement outlines comprehensive tax reforms, including a new investment booster with a 30% declining balance tax depreciation for equipment investments from 2025-2027 and a gradual reduction of the corporate income tax rate starting in 2028. Additionally, it proposes increasing the minimum trade tax rate, maintaining the solidarity surcharge, supporting international tax harmonization efforts, and refining taxation options for partnerships to ensure equitable treatment across business entities. Read TaxNewsFlash

United States

  • Notice 2025-23: Intent to propose removal of partnership basis shifting transactions of interest (TOI) regulations and withdrawing Notice 2024-54
  • Notice 2025-22: Nine items of IRB guidance (including Notice 2015-73 and Rev. Rul. 91-32) obsoleted in accordance with Executive Order 14219
  • White House announces extension of federal hiring freeze
  • Rev. Proc. 2025-18: Nationwide average purchase price, residences located in United States
  • U.S. Tax Court: Contracts were not “optionsâ€� under sections 1234 and 1234A because taxpayer in substance owned underlying securities
  • IRS practice units: FDAP payments; accounting method changes; qualified dividends and capital gains rate differential adjustments; home office and stewardship expenses; sourcing of multi-year compensation arrangements; child tax credit
  • IRS extends tax relief for North Carolina taxpayers due to Hurricane Helene
  • IRS provides tax relief for taxpayers in all of Arkansas and Tennessee
  • Delaware: Unclaimed property voluntary disclosure agreement (VDA) program mailings underway
  • ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø article: Recent developments in research credit audits and compliance

Read TaxNewsFlash-United States

Ìý

Transfer Pricing

  • Antigua and Barbuda: Country-by-country (CbC) reporting and transfer pricing rules; MCAA for CbC reports
  • Kazakhstan: New transfer pricing notification form for participation in MNE group
  • Poland: Proposed legislation amending Pillar Two rules
  • Germany: Coalition agreement includes plans for comprehensive tax reforms
  • OECD: Updated outcome of Pillar Two transitional peer review process
  • EU: Council adopts DAC9

Read TaxNewsFlash-Transfer Pricing

Africa

  • Angola: Individual income tax code proposal released for public consultation
  • Djibouti: Tax measures in Finance Law 2025
  • Nigeria: New online pension contribution system

Read TaxNewsFlash-Africa

Americas

  • Antigua and Barbuda: Country-by-country (CbC) reporting and transfer pricing rules; MCAA for CbC reports
  • Canada: New 10% tax on foreign purchasers of residential properties (Toronto)
  • Canada: Relief for businesses affected by tariffs
  • Canada: Tax measures in 2025 budget (Prince Edward Island)
  • Chile: Updated list of jurisdictions with preferential tax regimes; other direct and indirect tax developments
  • Dominican Republic: Proposed reduction of tax incentives across multiple sectors
  • Grenada: Indirect tax measures in 2025 budget
  • Mexico: Guidance on payment and calculation of tax on polluting gas emissions (Mexico City)
  • Saint Lucia: Amendment clarifies stamp duty exemption excludes immovable property

Read TaxNewsFlash-Americas

Asia Pacific

  • Armenia: Increased gambling tax rates
  • India: “Land or buildingâ€� includes leasehold rights; shares held as stock-in-trade versus capital assets; tax rate for private discretionary trusts (court decisions)
  • Kazakhstan: Extension of VAT payment by offset method on imported goods
  • Kazakhstan: New transfer pricing notification form for participation in MNE group
  • Malaysia: Tax developments summary (April 2025)
  • Saudi Arabia: Real estate transaction tax law, implementing regulations effective April 9, 2025
  • Taiwan: Guidance on pre-approval of net profit and domestic profit contribution ratios to calculate withholding tax
  • Turkey: Guide on tax treatment of donations
  • Turkey: Special consumption tax rates on certain tobacco products
  • Vietnam: Amended preferential import tax rates
  • Vietnam: Amendments to regulations on electronic invoices

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Draft program law includes first series of tax measures included in coalition agreement
  • Bosnia and Herzegovina: Proposed forgiveness of interest on tax debts (Republic of Srpska)
  • Denmark: Proposed legislation to implement cryptoasset reporting (DAC8)
  • EU: Council adopts DAC9
  • France: VAT exemption threshold reduction for small businesses postponed until June 1, 2025
  • Germany: Coalition agreement includes plans for comprehensive tax reforms
  • Greece: VAT exemption process for supply and intra-Community acquisition of certain goods
  • Ireland: European Commission approves modification and extension of film tax relief scheme
  • Italy: Implementation of obligation for non-EU companies operating in Italy through a fiscal representative to submit guarantee
  • Moldova: Consultations on implementation of various EU directives
  • OECD: Updated outcome of Pillar Two transitional peer review process
  • Poland: Deductibility of taxpayer’s own loans contributed to company; limitations on real property depreciation (court decisions)
  • Poland: Proposed legislation amending Pillar Two rules
  • Poland: Proposed postponement of certain elements of mandatory national electronic invoicing system (KSeF)
  • Romania: Guidance on VAT registration and use of e-invoicing in B2G transactions
  • Spain: Extended deadline for adapting e-invoicing software, new exemption in certain cases of invoicing by recipient or third party
  • Spain: Updated tax reporting requirements for financial sector
  • UK: Guidance removing blanket application of anti-abuse rule to capital contributions resulting in LLP member qualifying as genuine partner

Read TaxNewsFlash-Europe

FATCA / IGA / CRS

  • Australia: Circular on AEOI compliance improvement areas for reporting financial institutions
  • Germany: Updated CRS guidance
  • Singapore: Updated record level error codes for FATCA
  • UAE: Additional CRS guidance on “Undocumented Accountsâ€�

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • Canada: Relief for businesses affected by tariffs
  • EU pauses countermeasures against U.S. tariffs to allow for negotiations
  • USTR announces actions in Section 301 investigation of China's maritime sector dominance
  • Vietnam: Amended preferential import tax rates

Read TradeNewsFlash-Trade & Customs

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