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KPMG Week in Tax: February 2 – 6, 2026

Recent tax developments from around the globe for the week of February 2 – 6, 2026

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february 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).

  • United States: Proposed regulations for the section 45Z clean fuel production credit clarify eligibility, emissions rates, and certification requirements for producers of low-emission transportation fuels. The rules, which implement and expand on recent legislative changes, provide guidance for claiming credits, address industry concerns, and introduce new compliance requirements, with public comments due by April 6, 2026. Read TaxNewsFlash
  • France: Finance Act 2026 extends the exceptional corporate surtax for large companies (now applying to profits above €1.5 billion), introduces a new tax on certain non-professional assets held by holding companies, and implements OECD Pillar Two guidelines along with new EU rules for information exchange on global minimum tax compliance. Read TaxNewsFlash
  • India: The 2026-2027 Union Budget introduces tax holidays for foreign companies using data centers or supplying machinery to contract manufacturers, rationalizes minimum alternate tax provisions, extends the international financial services center (IFSC) holiday, and amends goods and services tax (GST) and customs duties. Significant transfer pricing changes include the rationalization of safe harbor rules, advance pricing agreements (APAs), and procedural changes. Read TaxNewsFlash

United States

  • Announcement 2026-3: Competent authority arrangement regarding arbitration process under U.S.-Spain income tax treaty
  • IRS provides tax relief for taxpayers affected by storms and flooding in Montana
  • Proposed regulations: Clean fuel production credit under section 45Z
  • Rev. Proc. 2026-12: Adequate disclosures for purposes of avoiding understatement penalties under section 6662(d) and preparer penalties under 6694(a)
  • U.S. Tax Court: Poultry producer’s R&D credits allowed to extent sufficiently documented
  • U.S. Tax Court: Securitization transaction failed to qualify as FASIT under sections 860H through 860L
  • KPMG article: Substantiation of compensation packages for R&D tax credits purposes

Read TaxNewsFlash-United States

Transfer Pricing

  • Australia: Final rules on exemptions from obligation to file Pillar Two tax returns
  • Belgium: Updated guidance on completion of CbC notification form
  • France: Tax measures in Finance Act 2026 include extension of windfall tax on large companies, amendments to Pillar Two rules
  • India: Tax measures in 2026-2027 budget include significant transfer pricing changes
  • Moldova: Citizenship services subject to VAT; certain interest-free loans not subject to transfer pricing rules; concurrent application of preferential tax regimes
  • Netherlands: Amendments to Pillar Two rules; planned implementation of Pillar Two side-by-side package
  • OECD: Revised manual on effective mutual agreement procedures (MAPs)

Read TaxNewsFlash-Transfer Pricing

FATCA / IGA / CRS

  • Cayman Islands: Extension of CRS 2.0 deadline
  • Channel Islands: Guidance Note on cryptoasset reporting framework (Jersey)
  • Finland: Implementation of CRS 2.0
  • Saint Kitts and Nevis: FATCA and CRS reporting deadline; AEOI compliance form
  • Switzerland: Updated CRS 2.0 guidance
  • United States: IRS updates FAQ on withholding foreign partnership (WP) and withholding foreign trust (WT) agreement renewals

Read TaxNewsFlash-FATCA / IGA / CRS

Trade & Customs

  • EU-Singapore digital trade agreement enters into force
  • President Trump signs AGOA reauthorization, extending duty-free trade benefits for eligible African countries
  • U.S. BIS removes Cambodia from U.S. arms embargoed country list under Export Administration Regulations
  • United States and Argentina sign reciprocal trade and investment agreement

Read TradeNewsFlash-Trade & Customs

Americas

  • Argentina: Recent indirect tax developments
  • Mexico: List of 272 registered foreign providers of digital services (as of December 31, 2025)
  • Mexico: New requirement to obtain certificate of state tax obligations (Quintana Roo)
  • Venezuela: Amended hydrocarbons law introduces new tax framework

Read TaxNewsFlash-Americas

Asia Pacific

  • Armenia: Income tax treaty with Japan entered into force
  • Australia: Final rules on exemptions from obligation to file Pillar Two tax returns
  • Cambodia: Simplified business registration procedure
  • Hong Kong: Consultation on proposals to enhance IP tax deduction regime
  • India: Capital gains exemption under Singapore treaty not available to shell company (tribunal decision)
  • India: Tax measures in 2026-2027 budget include significant transfer pricing changes
  • Korea: Changes to tax brackets for dividend income; 1% increase on corporate tax brackets
  • Korea: Tax measures to support domestic investment, foreign exchange stability
  • Philippines: Implementation of enhanced electronic documentary stamp system
  • Singapore: Updated guidance on GST for remote services, tax treatment of hybrid instruments
  • Uzbekistan: Proposed tax amendments for businesses, increased e-commerce tax rates in 2026
  • Uzbekistan: Tax incentives for textile industry, residents of creative parks

Read TaxNewsFlash-Asia Pacific

Europe

  • Andorra: Income tax treaty with UK enters into force
  • Belgium: Proposed change to VAT adjustment period for immovable business assets
  • Belgium: Updated guidance on completion of CbC notification form
  • Estonia: Reporting obligations for cryptoasset service providers (DAC8)
  • France: Tax measures in Finance Act 2026 include extension of windfall tax on large companies, amendments to Pillar Two rules
  • Germany: Deliveries did not qualify as VAT-exempt intra-community supplies; other VAT developments
  • Greece: Tax authority notifies non-compliant taxpayers on mandatory e-invoicing declaration
  • Hungary: Consultation on proposal to introduce mandatory e-invoicing
  • Moldova: Citizenship services subject to VAT; certain interest-free loans not subject to transfer pricing rules; concurrent application of preferential tax regimes
  • Moldova: Increase in VAT registration threshold; one-year extension of exemption for SMEs
  • Moldova: VAT self-assessment declaration for traders of electricity and natural gas
  • Netherlands: Amendments to Pillar Two rules; planned implementation of Pillar Two side-by-side package
  • Netherlands: Income tax treaty with Thailand signed
  • Netherlands: Proposed tax measures in minority coalition agreement
  • Norway: Tax authority claims that joint Nordic audit focused on securities lending practices reveals avoidance of dividend withholding tax
  • Romania: Repeal of tax on “nonresident affiliates”; transition period for individuals using e-invoicing system
  • Serbia: Amended rulebook on electronic delivery notes
  • UK: Interests held by managing directors and partners of consulting firm not respected as capital interests (Upper Tribunal decision)
  • UK: Update on Finance Bill 2025-2026

Read TaxNewsFlash-Europe

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