KPMG Week in Tax: January 5 – 9, 2026

Recent tax developments from around the globe for the week of January 5 – 9, 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).

OECD: The OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) reached agreement on key elements of a “side-by-side” package allowing for continued coordinated operation of Pillar Two global minimum tax arrangements. KPMG LLP has published a report providing preliminary observations and analysis. Read TaxNewsFlash
Belgium: The Local file form (275 LF) has been amended for financial years starting January 1, 2025, streamlining compliance by no longer requiring taxpayers to proactively submit supporting transfer pricing documents with the form. Instead, taxpayers must simply indicate in the form whether such documents are readily available. Read TaxNewsFlash
Japan: The ruling coalition has agreed to an outline of tax reform proposals for 2026, which includes measures to promote investment, R&D, salary increases, and domestic production, as well as updates to global minimum tax rules and new consumption and individual tax provisions. Details are subject to change during the legislative process, but key areas targeted include corporate incentives, international tax compliance, and cryptoassets. Read TaxNewsFlash

United States

Proposed regulations: Backup withholding on third party network transactions
Announcement 2026-2: Confirmation that tax under section 4611 for 2026 does not include “oil spill tax”
Rev. Proc. 2026-10: Guidance on process for requesting PLRs for consent to make retroactive QEF election under section 1295
KPMG report: Treatment of domestic R&E expenditures under OBBBA—state tax and important federal considerations
KPMG report: Regulatory perspectives on accounting for income taxes
KPMG report: Overview of Pillar Two side-by-side package

Read TaxNewsFlash-United States

Transfer Pricing

OECD: Agreement reached on Pillar Two side-by-side package
KPMG report: Overview of Pillar Two side-by-side package
Bahrain: Draft law introducing 10% corporate income tax referred to legislative authorities; updated guide on scope of domestic minimum top-up tax (DMTT)
Belgium: Amended Local file form
Costa Rica: Adjusted deadlines for transfer pricing information statements
Japan: Outline of 2026 tax reform proposals, including amendments to Pillar Two rules
North Macedonia: VAT law amendments; new guidance on Pillar Two top-up tax

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

Cayman Islands: Quick guide on cryptoasset reporting framework (CARF)
Germany: Updated CRS guidance; implementation of DAC8 and CARF
Liechtenstein: Cryptoasset reporting framework (CARF) regulation enacted
Moldova: Amended list of AEOI participating and reportable jurisdictions
Spain: Updated guidance on common errors in CRS reports received via Form 289

Read TaxNewsFlash-FATCA / IGA / CRS

Africa

Ghana: Modified taxation scheme for “informal sector”
Kenya: Digital platform operator with transactional control liable for VAT (High Court decision)
Kenya: New standards levy on manufacturing turnover
Kenya: Tax return information to be validated against specified data sources
Mozambique: Amendments to VAT, corporate and individual income tax, excise tax, and customs laws
Namibia: Tax proposals in 2025/2026 mid-year budget review
Nigeria: “Certified” versions of tax reform legislation released by National Assembly

Read TaxNewsFlash-Africa

Americas

Argentina: Changes to tax procedure law
Argentina: Recent indirect tax developments
Barbados: Repeal of 2019 economic substance law; passage of Economic Diversification and Growth Fund Act 2025
Brazil: Amendments to indirect tax reform adopted
Brazil: Temporary four-month waiver of penalties for tax on goods and services and VAT invoice obligations in early 2026
Canada: 2025 direct and indirect tax rates and other changes to consider for tax accounting purposes
Cayman Islands: No new taxes proposed in 2026-2027 budget
Chile: Guidance on timing of listing condition for special capital gains regime for listed shares
Costa Rica: Adjusted deadlines for transfer pricing information statements
Honduras: Updated 2026 withholding table for income tax
Mexico: General foreign trade rules for 2026; amendments to import and export duties law
Mexico: Miscellaneous tax resolution for FY2026 clarifies effect of 2026 tax reform on digital services providers and platforms intermediaries
Mexico: Presidential decree grants excise tax credit on violent-content video games
Mexico: Revision of e-invoicing (CFDI) complement for digital platforms
Saint Lucia: Withholding tax on payments to nonresident parent company upheld (Caribbean Court of Justice decision)

Read TaxNewsFlash-Americas

Asia Pacific

Bahrain: Draft law introducing 10% corporate income tax referred to legislative authorities; updated guide on scope of domestic minimum top-up tax (DMTT)
Cambodia: Cabinet approves tax treaties with Laos, Philippines, Singapore
Cambodia: Implementation of capital gains tax further delayed to 2026
China: Implementation regulations under updated VAT law
New Zealand and Croatia: Income tax treaty signed
India: Summary of 2025 tax developments
Japan: Outline of 2026 tax reform proposals, including amendments to Pillar Two rules
Malaysia: Direct and indirect tax measures in Finance Act 2025
Malaysia: Tax changes related to stamp duty, sales and service tax, and e-invoicing
Saudi Arabia: Updated VAT on deemed suppliers guidelines; amendments to excise tax on sweetened beverages
Singapore: Guidance on tax classification of foreign entities, taxation of fees paid to nonresidents under tender offer for qualifying debt securities
Sri Lanka: Strategic Development Projects (Amendment) Act, No. 26 of 2025
Taiwan: Procedures for claiming tax deductions on scrapped fixed assets
Turkey: Disputes relating to classification of hybrid vehicles under special consumption tax law must be resolved through litigation
Turkey: Guide on taxation of non-profit entities
UAE: Changes to excise tax rates for sweetened drinks
Vietnam: Guidance on customs procedures and tax administration for import and export goods
Vietnam: Guidance on new international financial centers regime

Read TaxNewsFlash-Asia Pacific

Europe

Belgium: Amended Local file form
Bosnia and Herzegovina: Instructions for VAT refund procedures for nonresidents
Bulgaria: New VAT regimes for supplies of goods by EU supplies, small enterprises
Croatia and New Zealand: Income tax treaty signed
Cyprus: Guidance on VAT treatment of admissions to events
Greece: Guidance on taxation of distribution or capitalization of untaxed profits from prior years
Greece: Guidance on timing of deductions during balancing market settlement process, tax incentive regime for corporate reorganizations
Greece: Income tax treaty with UAE once again in force
Greece: List of countries with preferential tax regimes for FY2023; list of non-cooperative countries for FY2024
Liechtenstein: Income tax treaties with Latvia and Montenegro approved by Parliament
Luxembourg: Amending protocols to income tax treaties with Georgia and San Marino approved; tax treaty with Montenegro effective October 1, 2025
Moldova: Guidance on application of SME tax regime
Moldova: Guidance on application of VAT to sales conducted abroad, commissions charged by freelance services platforms, electricity and gas supplies
North Macedonia: VAT law amendments; new guidance on Pillar Two top-up tax
UK: Draft guidance on new advance tax certainty service (ATCS)
UK: Providing scientific education through digital platform does not qualify for R&D tax relief (First-tier Tribunal decision)
UK: Stamp duty land tax general anti-avoidance rule applied to series of intra-group transactions (Court of Appeal decision)

Read TaxNewsFlash-Europe

Other publications

The items described above are also reported as editions of TaxNewsFlash:

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