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KPMG Week in Tax: April 20 – 24, 2026

Recent tax developments from around the globe for the week of April 20 – 24, 2026

April 27, 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).

  • Belgium: A proposed bill would introduce a 3% digital services tax effective January 1, 2027, for multinational groups with over €750 million in annual global revenue and €3 million in Belgian digital revenue. The tax applies to gross revenue from targeted advertising, digital intermediation, and user data monetization involving users located in Belgium. Read TaxNewsFlash
  • Philippines: The Bureau of Internal Revenue clarified that cross-border services are not automatically subject to income tax, but are instead evaluated based on where the service is completed or the benefit is received. Taxpayers can substantiate that income is sourced outside the country and exempt from local tax by providing specific documentation such as service contracts, invoices, and tax residency certifications. Read TaxNewsFlash
  • United States: The U.S. Court of Appeals for the Tenth Circuit affirmed the denial of a taxpayer's $109 million refund claim, holding that the codified economic substance doctrine under section 7701(o) was relevant to its 2018 transaction. The court determined the doctrine applies when transactions serve no economic purpose other than to mechanically exploit tax code provisions, such as the section 245A deduction, for unintended tax benefits. Read TaxNewsFlash

United States

  • Tenth Circuit: Taxpayer’s refund claim denied under economic substance doctrine
  • IRS issues updated FAQs regarding educational assistance programs
  • KPMG article: Importance of aligning IP ownership with where value is created

Read TaxNewsFlash-United States

  • Senate passes clean FY 2026 budget resolution
  • FY 2026 budget resolution does not include tax

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Australia: Updated guidance on transfer pricing for inbound distribution arrangements
  • Finland: New guidance issued on application of Pillar Two safe harbor provisions
  • Georgia: New reporting obligation for international controlled transactions
  • Hungary: Amendments to GloBE notification form
  • Iceland: Transfer pricing assessment upheld based on incomplete taxpayer documentation (Court of Appeals decision)
  • KPMG article: Importance of aligning IP ownership with where value is created
  • KPMG article: Updated OECD manual on mutual agreement procedures (MAPs)
  • Liechtenstein: Consultation on implementation of Pillar Two side-by-side package and exchange of GloBE information returns
  • Luxembourg: Additional tax measures in law implementing DAC8
  • Montenegro: Implementation of Pillar Two global minimum tax rules

Read TaxNewsFlash-Transfer Pricing

FATCA / CRS / CARF

  • Bahamas: AEOI registration and reporting deadlines
  • Finland: Updated FATCA and CRS FAQs on implementation of CRS 2.0
  • Japan: Updated CRS FAQs
  • Luxembourg: Additional tax measures in law implementing DAC8

Read TaxNewsFlash-FATCA / CRS / CARF

Trade & Customs

  • Burkina Faso: Customs measures in Finance Law
  • EU-Mercosur free trade agreement: Provisional application begins May 1, 2026
  • Republic of the Congo: Customs and VAT relief on certain essential goods imports
  • UAE: Customs-related economic initiatives package approved (Dubai)
  • United States: CBP launches IEEPA duty refund tool

Read TradeNewsFlash-Trade & Customs

Africa

  • Burkina Faso: Direct and indirect tax measures in Finance Law
  • Cameroon: Introduction of mandatory real-time e-invoicing
  • Republic of the Congo: Customs and VAT relief on certain essential goods imports

Read TaxNewsFlash-Africa

Americas

  • Canada: Federal and Ontario measures related to housing rebates
  • Colombia: Proposed new customs regimes for assembly of electric and hybrid vehicles
  • Dominican Republic: Excise tax updates and court decisions (March 2026)
  • EU-Mercosur free trade agreement: Provisional application begins May 1, 2026

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Updated guidance on transfer pricing for inbound distribution arrangements
  • India: Taxpayer could not be treated as partial tax resident under Kazakhstan treaty (tribunal decision)
  • Kazakhstan: Proposed amendments to Tax Code
  • Oman: Draft specifications for e-invoicing framework
  • Philippines: Guidance on taxation of cross-border services
  • Qatar: Capital gains tax advantage for group restructuring transactions
  • Qatar: Direct application of treaty withholding tax provisions
  • Türkiye: Proposed direct and indirect tax amendments, including formal cryptoasset taxation framework
  • UAE: Customs-related economic initiatives package approved (Dubai)

Read TaxNewsFlash-Asia Pacific

Europe

  • Austria: VAT on roaming services used in Austria upheld (Supreme Administrative Court decision)
  • Belgium: Proposal to introduce digital services tax
  • Bulgaria: New enhanced R&D deduction enacted
  • EU-Mercosur free trade agreement: Provisional application begins May 1, 2026
  • Finland: New guidance issued on application of Pillar Two safe harbor provisions
  • France: Capital ownership non-discrimination clause of Swiss treaty does not extend French horizontal tax consolidation regime (Supreme Administrative Court decision)
  • France: Guidelines on new dividend withholding tax rules
  • France: VAT ruling on dropshipping
  • Georgia: New reporting obligation for international controlled transactions
  • Greece: Clarification of VAT exemption for telemedicine services; special method of input VAT deduction on immovable property
  • Greece: Taxpayers must prove expenses in transactions with foreign companies not aimed at tax evasion (Supreme Administrative Court decision)
  • Hungary: Amendments to GloBE notification form
  • Hungary: Advertisement tax regime temporarily suspended
  • Iceland: Transfer pricing assessment upheld based on incomplete taxpayer documentation (Court of Appeals decision)
  • Ireland: Updated guidance on outbound payments defensive measures
  • Italy: “Commercial activity” requirement for participation exemption (Supreme Court decision)
  • Italy: Guidance on application of elective alternative CFC tax
  • Liechtenstein: Consultation on implementation of Pillar Two side-by-side package and exchange of GloBE information returns
  • Lithuania: Tax card for 2026
  • Luxembourg: Additional tax measures in law implementing DAC8
  • Luxembourg: Increased depreciation for energy renovations of rental dwellings
  • Montenegro: Implementation of Pillar Two global minimum tax rules
  • Netherlands: Public consultation on additional dividend stripping measures
  • Norway: Consultation on VAT rules for remote services
  • Norway: New CO2 tax exemptions for emissions trading system-covered entities
  • Poland: New version of proposed legislation amending VAT law; other tax developments
  • Türkiye: Proposed direct and indirect tax amendments, including formal cryptoasset taxation framework

Read TaxNewsFlash-Europe

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