Skip to main content

Downloading a new tax in the Golden State – California’s new software tax explained

07.22.2026 | Duration: 59:09

California has enacted major changes to its taxation of prewritten software, effective January 1, 2027. The new law extends the state's sales and use tax to downloaded and remotely accessed software for the first time, impacting nearly every business operating in the state.

Listen now
0:00
00:00

In this episode of This Week in State Tax, host Harley Duncan is joined by Jim Kuhl, a Director in KPMG's Sacramento office, to discuss the significant implications of California's new budget trailer bill, S.B. 122. Signed into law in June 2026, this bill overhauls the state's approach to sales and use tax by expanding its reach to prewritten software that is downloaded or accessed remotely.

Harley and Jim break down what this change means for any business that sells, buys, or has users of software in California. They cover key aspects of the new law, including specific exemptions for certain digital products, the new sourcing rules based on customer addresses, and a potential tax trap involving out-of-state software use. The discussion also explores a unique $5 million sales threshold that shifts the tax reporting responsibility from the seller to the buyer, requiring the buyer to obtain a use tax direct pay permit. Tune in to understand these critical changes and learn about upcoming guidance from the California Department of Tax and Fee Administration (CDTFA).

Meet our podcast team

Image of Harley T. Duncan
Harley T. Duncan
Consultant to KPMG
Read bio
Image of Harley T. Duncan

Harley T. Duncan

Consultant to KPMG

Harley T. Duncan is a consultant to the KPMG State and Local Tax practice. He joined KPMG in 2008 and served as leader of the Washington National Tax State and Local Tax Group through 2021. Harley spent the previous 20 years as Executive Director of the Federation of Tax Administrators and has worked with Kansas and South Dakota state governments. He focuses on sales, use and excise taxes as well as matters of state tax policy and tax administration and assists KPMG with the weekly This Week in State Tax (TWIST) publication and podcast series.

Image of James C Kuhl
James C Kuhl
Director, Tax, KPMG US

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline