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KPMG report: Transfer pricing and international 2026 tax considerations

Issues expected to factor into how MNEs plan for the future

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january 20, 2026

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.

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