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International review for February 2025

This month’s review by Tim Sarson (KPMG) includes insight on the latest developments from the US Administration and the European Community.

US tax update

Presidential Memorandums on tax

At the time of writing my January 2025 update President Trump had just issued a Memorandum to the Secretary of the Treasury withdrawing US support from the OECD ‘Global Tax Deal’ and giving officials 60 days (approximately until 20 March 2025) to draw up retaliatory measures against countries applying levies on US headquartered groups that are ‘extraterritorial or disproportionately affect American companies’.

On 20 January 2025 President Trump issued another Memorandum entitled ‘America First Trade Policy’ that instructs a separate investigation into whether ‘any foreign country subjects United States citizens or corporations to discriminatory or extraterritorial taxes pursuant to section 891 of title 26 United States Code’. Section 891 states that when the President declares there is such discrimination ...

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