Global Tax & Regulatory Updates

29th May 2025

The week of 23-29 May 2025 saw significant movement across international tax and regulatory landscapes. From the United States’ rollout of detailed crypto tax reporting rules, to the OECD’s push for transfer pricing reform and EU scrutiny on cross-border compliance, this week offered critical insights for high-net-worth individuals (HNWIs), multinational firms, and wealth advisors.

These developments highlight a tightening global tax net, particularly for those with cross-border assets, decentralised finance exposure, or complex holding structures. Below is a breakdown of the key updates, what they mean for your planning, and what to monitor going forward.

Key Market Developments

United States IRS Details Digital Asset Reporting Delays

As of late May 2025, the Internal Revenue Service (IRS) has not issued any new updates regarding the implementation or further delay of digital asset broker reporting rules. The rules, originally introduced under the Infrastructure Investment and Jobs Act, are still expected to come into effect on 1 January 2026, as per the last available guidance from 2024.

This means crypto exchanges, custodians, and wallet providers should continue preparations to comply, and HNWIs with digital asset exposure are strongly advised to maintain detailed transaction records in anticipation of full tax transparency requirements.

OECD Advances Pillar One & Transfer Pricing Guidance

The OECD held its annual Tax and Development Days event during the week, where it introduced further clarity on Pillar One implementation and transfer pricing frameworks for multinational enterprises. The OECD’s new draft guidance includes:

• A proposed harmonised approach for valuing cross-border intangibles
• Rules targeting base erosion through pricing mismatches between jurisdictions
• An update to documentation standards aligned with country-by-country reporting (CbCR)

These frameworks are central to the OECD’s global tax deal, and their adoption could significantly impact HNWIs and business owners with IP-heavy or multi-jurisdictional structures.

UK HMRC Flags Targeted Wealth Audits

HMRC this week confirmed a new round of “targeted compliance campaigns” aimed at UK-resident non-domiciled individuals and overseas property owners. The campaign, part of HMRC’s £1 billion investment in digital enforcement, will prioritise:

• Unreported offshore trusts and foundations
• Foreign rental income
• Gains realised through offshore holding companies

Letters are expected to begin issuing in June, with the first batch targeting wealth structures not previously disclosed under the Requirement to Correct (RTC) regime.

European Commission to Investigate Beneficial Ownership Compliance

The European Commission launched an audit review into beneficial ownership registers across member states, citing inconsistencies in transparency enforcement and growing evidence of shell structure misuse. Early findings revealed that over 40% of national registers fail to verify declarations, enabling tax avoidance and asset shielding.

For wealth managers and family offices operating across EU jurisdictions, this increases the urgency to validate structures and reporting integrity, particularly under the Anti-Money Laundering Directive (AMLD6) and DAC7.

India Expands Scope of Crypto Tax Rules

India’s Ministry of Finance issued a clarification circular on 28 May 2025, stating that the 1% Tax Deducted at Source (TDS) on crypto transactions will also apply to off-market peer-to-peer (P2P) transactions and NFT trades.

This effectively brings private wallet transactions into the tax net, a notable escalation in India’s push to formalise crypto taxation. The circular also warned platforms of penalties for failing to deduct and remit TDS at the time of transaction.

Implications for Investors and Businesses

For High-Net-Worth Individuals:

• Crypto investors must prepare for full transparency: Even where reporting is delayed (e.g. in the U.S.), maintaining clean records and tax-aligned transaction histories will be essential for future compliance.
• Non-dom UK residents should proactively review offshore structures, especially trusts or foreign property held through layered entities. HMRC’s new focus suggests tighter enforcement is imminent.
• Cross-border holding companies will face higher scrutiny under both OECD transfer pricing rules and EU beneficial ownership directives. Legal and tax reviews should be scheduled ahead of any liquidity events or dividend repatriations.

For Businesses and Wealth Advisors:

• MNEs must brace for Pillar One recalibrations, especially if operating across digital services, pharma, or IP-intensive industries. The new transfer pricing documentation rules will require updated benchmarking models and CbCR alignment.
• Crypto platforms operating in India or serving Indian clients must now implement TDS frameworks across all types of crypto and NFT trades, even those occurring off-chain.
• Family offices in EU jurisdictions will need to verify the transparency of nominee shareholder arrangements and ensure that BO registers reflect economic reality, or risk cross-border reporting penalties.

Conclusion & Next Steps

This week’s updates show a steady international trend toward transparency, data sharing, and enforcement precision. HNWIs and globally connected businesses should not view the staggered implementation of new rules as a reprieve, but as a short window to realign tax positions and reporting structures.

What to Look Out for in the Coming Weeks:

• U.S. Treasury’s next guidance on Form 1099-DA for digital asset brokers.
• OECD consultation deadlines on revised Pillar One and transfer pricing frameworks.
• New wave of UK compliance letters targeting unreported foreign property income.
• EU updates on DAC8, focusing on crypto and cross-border investment structures.
• India’s enforcement reports on TDS collections from crypto/NFT markets.

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