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KPMG report: Transfer pricing and international tax year-end considerations

Key developments and emerging issues for multinational enterprises looking ahead to 2027.

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september 22, 2026

Multinational enterprises (MNEs) continue to navigate the practical effects of the “One Big Beautiful Bill Act” (OBBBA) and the OECD’s Pillar Two side-by-side (SbS) package, as well as qualified domestic minimum top-up taxes (QDMTTs) and ongoing Pillar Two compliance.

Looking ahead to 2027, MNEs may need to prepare for potential OECD guidance on global mobility and intragroup services, draft U.S. regulations on Amount B, OECD guidance on the digital economy, and an evolving transfer pricing controversy landscape.

Read a September 2026 report prepared by KPMG LLP

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