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KPMG Week in Tax: January 12 – 16, 2026

Recent tax developments from around the globe for the week of January 12 – 16, 2026

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january 19, 2026

KPMG Week in Tax—published weekly to provide an overview of tax developments as reported in TaxNewsFlash—includes summaries of select tax-related news followed by a full list of reports (more information can be found at the links provided).

  • United States: The IRS issued interim guidance (Notice 2026-11) on the permanent 100% first-year depreciation deduction for eligible property acquired and placed in service after January 19, 2025, as reinstated by the One Big Beautiful Bill Act (OBBBA). The notice also expands eligibility to certain sound recording productions and provides options for alternative depreciation elections. Read TaxNewsFlash
  • United States: President Trump signed a proclamation imposing an immediate 25% tariff on certain advanced computing chips, with some exemptions for chips used in the United States. The Trump Administration also announced new negotiations and possible future actions targeting imports of processed critical minerals. Read TradeNewsFlash
  • EU: The Court of Justice of the European Union (CJEU) published the non-binding opinion of its Advocate General (AG) regarding the value added tax (VAT) treatment applicable to transfer pricing adjustments. The AG suggested that pure adjustments for income tax purposes are outside the scope of VAT, while adjustments that relate to real transactions and agreed between the parties should be considered an adjustment to the initial price and not result in a separate provision of services. Read TaxNewsFlash
  • Vietnam: The new tax administration law, effective July 1, 2026, shortens the period for supplementing tax declarations to five years, tightens rules on indirect capital transfer tax withholding, and streamlines tax audit timelines. The law also updates advance pricing agreement (APA) procedures, expands tax authorities’ enforcement powers, and increases reporting obligations for banks and income payers. Read TaxNewsFlash

United States

  • Fifth Circuit: “Limited partner” for purposes of exception to self-employment income means a partner in limited partnership with limited liability
  • Notice 2026-11: Interim guidance on permanent 100% additional first-year depreciation deduction under section 168(k), as reinstated by OBBBA
  • Notice 2026-13: Modified safe harbor explanations for retirement plan administrators
  • Notices of filing of petitions for addition of five substances to Superfund list
  • Rev. Rul. 2026-4: Alaska Railroad Corporation bonds for LNG project exempt from private activity bond requirements
  • KPMG report: What’s new in energy credits for 2026
  • KPMG article: IRS keeps focus on R&D tax credit even as agency staff shrinks

Read TaxNewsFlash-United States

Legislative Updates

  • JCT list of expiring federal tax provisions, 2025–2035

Read TaxNewsFlash-Legislative Updates

Exempt Organizations

  • Rev. Proc. 2026-8: Updated procedures for obtaining and maintaining group tax-exemption under section 501(c)

Read TaxNewsFlash-Exempt Organizations

Transfer Pricing

  • Cameroon: Guidance on mutual agreement procedures (MAPs)
  • EU: EC notice confirming application of Pillar Two side-by-side package under EU minimum tax directive
  • EU: Priorities of Cyprus EU Council Presidency; state of play on implementation of DAC8 and DAC9
  • EU: Transfer pricing adjustment only relevant for VAT purposes if qualified as adjustment of transaction price agreed between parties (CJEU Advocate General opinion)
  • Luxembourg: Pillar Two registration and reporting forms
  • Romania: Public consultation on guidance for GloBE information return
  • Sweden: Draft legislation implementing DAC9
  • Vietnam: Changes in new tax administration law, including to APA procedures
  • KPMG report: 2025 update to OECD Model Tax Convention

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Bahamas: Amendments to automatic exchange of financial information law
  • Monaco: Protocol amending AEOI agreement with EU effective January 1, 2026

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • United States imposes immediate 25% tariff on certain advanced computing chips
  • U.S. BIS revises license review policy for exports of certain semiconductors to China and Macau
  • U.S. CBP modifies withhold release order on certain palm oil products from Malaysia

Read TradeNewsFlash-Trade & Customs

Africa

  • Cameroon: Guidance on mutual agreement procedures (MAPs)
  • Ethiopia: Proposed tax incentives for exports, startups, green energy projects
  • Liberia: Draft 2026 budget includes measures to tax digital economy, increase in GST
  • Mauritius: VAT obligations of foreign suppliers of digital and electronic services effective January 1, 2026
  • Niger: Expanded solidarity fund contribution introduces various levies and tax incentives
  • Nigeria: New 15% import duty on fuel; other recent tax-related developments
  • Tunisia: Expanded e-invoicing mandate to cover services, in addition to goods

Read TaxNewsFlash-Africa

Americas

  • Argentina: Improvements to advance tax payment reduction regime
  • Dominican Republic: Guidance regarding application of territoriality principle for tax residents
  • Jamaica: Import duty and general consumption tax relief to support Hurricane Melissa recovery efforts
  • Mexico: Extension of tax incentives for border regions and fuels
  • Trinidad and Tobago: New taxes in Finance Act 2025 include commercial asset levy

Read TaxNewsFlash-Americas

Asia Pacific

  • Bahrain: Tax treaty with Oman effective September 16, 2025
  • India: Costs incurred by Singapore taxpayer and cross-charged to its Indian branch deductible in computing branch’s profits under Singapore treaty (tribunal decision)
  • India: Transfer of shares held as stock-in-trade pursuant to amalgamation results in taxable business income (Supreme Court decision)
  • Malaysia: Tax developments summary (January 2026)
  • Qatar: Protocol to income tax treaty with Norway ratified
  • Vietnam: Changes in new tax administration law, including to APA procedures

Read TaxNewsFlash-Asia Pacific

Europe

  • Cyprus: Repeal of stamp duty laws
  • Cyprus: Tax reform legislation enacted and effective January 1, 2026
  • Estonia: Income tax treaties with Liechtenstein and Oman ratified
  • EU: Carbon border adjustment mechanism (CBAM) successfully entered into force on January 1, 2026
  • EU: CJEU referral on compatibility with EU law of Germany’s double tax relief switch-over mechanism for foreign PEs
  • EU: CJEU referral on Portugal’s regime imposing increased property tax rates on real estate held through tax haven structures
  • EU: EC notice confirming application of Pillar Two side-by-side package under EU minimum tax directive
  • EU: Priorities of Cyprus EU Council Presidency; state of play on implementation of DAC8 and DAC9
  • EU: Transfer pricing adjustment only relevant for VAT purposes if qualified as adjustment of transaction price agreed between parties (CJEU Advocate General opinion)
  • France: VAT exemption thresholds for goods, accommodations, and services reinstated retroactively to March 1, 2025
  • Germany: Updated FAQ on mandatory e-invoicing
  • Greece: Guidance on implementation of carbon border adjustment mechanism (CBAM)
  • Hungary: Entry into force of amending protocol to Switzerland income tax treaty
  • Luxembourg: Pillar Two registration and reporting forms
  • Netherlands: Foreign tax credits to alleviate double taxation of assets from trusts (APVs)
  • Romania: Amendments to various direct and indirect taxes, new e-invoicing obligations
  • Romania: Public consultation on guidance for GloBE information return
  • Slovenia: Changes to taxation of derivative financial instruments and corporate income tax
  • Spain: VAT-related compliance for January and February 2026
  • Sweden: Draft legislation implementing DAC9
  • Sweden: Proposed enhancements to tonnage taxation system
  • Switzerland: Federal Council approves income tax treaty with Zimbabwe

Read TaxNewsFlash-Europe

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