KPMG report: Transfer pricing and international 2026 tax considerations
Issues expected to factor into how MNEs plan for the future
As companies prepare for 2026, several transfer pricing and international tax issues are expected to factor into how multinational enterprises (MNEs) plan for the future:
- Pillar Two: “side-by-side package” and transfer pricing considerations
- Planning in light of the “One Big Beautiful Bill Act”
- Reducing the impact of tariffs
- Public country-by-country (CbC) reporting
- Planning for upcoming OECD initiatives
- Planning for evolving business models and new technology
- Transfer pricing controversy
- Corporate alternative minimum tax (CAMT)
- Key upcoming changes in the transfer pricing compliance landscape
Read a January 2026 report prepared by KPMG LLP that examines these issues and developments.