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ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Week in Tax: April 28 â€� May 2, 2025

Recent tax developments from around the globe for the week ofÌýApril 28 â€� May 2, 2025

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May 2, 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).

  • Canada: The Liberal Party of Canada is set to form the government following the results of the recent federal election. The Liberal Party’s tax promises made during the election offer insight into potential tax changes for business and individuals that could be announced in the coming months or included in the next federal budget. Read TaxNewsFlash
  • United States: President Trump nominated Donald Korb, who formerly served as IRS Chief Counsel from 2004-2008, to serve as the next IRS Chief Counsel. Read TaxNewsFlash
  • United States: The White House announced offsets to a portion of tariffs on imports of automobile parts into the United States. Read TradeNewsFlash
  • UK: HMRC publishedÌýdraft legislationÌýfor consultation to reform the UK’s transfer pricing, permanent establishment (PE), and diverted profits tax (DPT) rules. The proposals are aimed at simplifying and updating the UK’s international tax rules and aligning them more closely with the UK’s obligations under its income tax treaties. The legislation would become effective no earlier than January 1, 2026. Read TaxNewsFlash

United States

  • Trump nominates Donald Korb as IRS Chief Counsel
  • Rev. Proc. 2025-20: Foreign insurance companies; effectively connected net investment income (2024)
  • Rev. Proc. 2025-19: HSA inflation-adjusted amounts for 2026
  • IRS practice units: Foreign tax redeterminations; failure to file Form 3520/3520-A penalties
  • IRS provides tax relief for taxpayers affected by storms in Virginia

Read TaxNewsFlash-United States

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Transfer Pricing

  • Bahrain: Updated domestic minimum top-up tax (DMTT) registration manual
  • Germany: Guidance on new transaction matrix transfer pricing document requirement; other tax developments
  • Kazakhstan: New information system for submitting Local file
  • UAE: Retroactive implementation of OECD Pillar Two guidance
  • UK: Consultation on draft legislation to reform transfer pricing, PE, and DPT rules
  • UK: Consultation on proposals to extend scope of transfer pricing rules to medium enterprises, introduce new reporting requirements

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Finland: Enhancements to check routines for CRS / DAC2
  • South Africa: Change in SARSQA Connect Direct Public Certificate
  • UAE: Updated FATCA FAQs and U.S. TIN reporting requirements

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • White House announces adjustments to tariffs on imports of automobile parts
  • White House issues executive order on “tariff non-stackingâ€�
  • U.S. BIS establishes Section 232 steel and aluminum tariff inclusions process
  • USTR releases 2025 “Special 301 Reportâ€� on protecting intellectual property rights

Read TradeNewsFlash-Trade & Customs

Americas

  • Canada: Effect of 2025 election on potential tax changes
  • Costa Rica: Consultations on fiscal periods, tax forms, submission of VAT returns
  • Mexico: Guidelines for property tax relief for fiscal year 2025 (Mexico State)

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Superannuation tax updates
  • India: Damages received for failure of property development contract not taxable as capital gains (tribunal decision)
  • India: Permanent establishment losses deductible against fee for technical services income under Korea treaty (tribunal decision)
  • India: Guidance on when settlement payments cannot be claimed as deductions
  • Kazakhstan: New information system for submitting Local file
  • Malaysia: Deferral of service tax expansion, sales tax review
  • Pakistan: Corporate and non-corporate registered persons required to register digitally
  • Saudi Arabia: VAT amendments approved, effective immediately
  • UAE: Retroactive implementation of OECD Pillar Two guidance

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Proposed capital gains tax on financial assets
  • Cyprus: “Defensiveâ€� tax measures for payments to EU non-cooperative and low-tax jurisdictions
  • EU: Member states express concerns regarding Clean Industry State Aid Framework proposal
  • EU: Targeted consultation on barriers to EU capital markets integration
  • Finland: Consultation on amendments to interest deduction limitation rules for critical entities financing long-term infrastructure projects
  • Germany: Guidance on new transaction matrix transfer pricing document requirement; other tax developments
  • Germany: VAT reforms included in coalition agreement; other VAT developments
  • Gibraltar: Proposed changes to income tax anti-avoidance rules
  • Greece: New law introduces tax incentives for investors and corporate transformations
  • Lithuania: Tax proposals include corporate tax increase, tax incentives for asset acquisitions and small enterprises
  • Netherlands: Taxpayers not subject to anti-abuse rule for nonresident taxation of personal holding companies (Supreme Court decisions)
  • Poland: Clearance opinion approving group restructuring
  • Poland: Liability of board member for company’s tax debts (CJEU judgment)
  • Poland: Property tax exemption does not appear to constitute illegal State aid (CJEU judgment)
  • Poland: VAT on granting power of attorney; grid connection fees and contractual penalties as tax-deductible costs (Supreme Administrative Court decisions)
  • UK: Consultation on draft legislation to reform transfer pricing, PE, and DPT rules
  • UK: Consultation on proposals to extend scope of transfer pricing rules to medium enterprises, introduce new reporting requirements
  • UK: Updated HMRC guidance on real estate investment trusts (REITs)

Read TaxNewsFlash-Europe

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