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KPMG Week in Tax: September 21 – 25, 2026

Recent tax developments from around the globe for the week of September 21 – 25, 2026

september 28, 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 U.S. Tax Court held that the 90-day deadline for a partnership to petition for review of a Final Partnership Adjustment under the BBA partnership audit regime is subject to equitable tolling. The court further held that equitable tolling applied because the partnership diligently pursued its rights and extraordinary circumstances outside its control prevented a timely filing. Read TaxNewsFlash
  • United Kingdom: HMRC’s new international controlled transactions schedule (ICTS), expected to apply for accounting periods beginning on or after January 1, 2027, will require certain companies to report information on cross-border related-party transactions and permanent establishment dealings. HMRC intends to use the information for automated transfer pricing and permanent establishment (PE)  risk profiling and identification. Read TaxNewsFlash
  • Australia: The ATO released draft guidance addressing the income tax treatment of cryptoasset airdrops and the capital gains tax consequences of wrapping and unwrapping cryptoassets through smart contracts. The guidance comes ahead of CGT changes from July 1, 2027, including new capital loss ordering rules and a 30% minimum tax on capital gains. Read TaxNewsFlash

United States

  • Notice 2026-52: Extension of relief from failure to deposit penalties related to new excise tax on certain remittance transfers
  • Notice 2026-55: Request for comments on issues under section 1400Z-2 regarding investments in QOFs and QOZ businesses
  • Notice 2026-60: Per diem rates, substantiation of employee lodging, meals, incidentals (2026-2027)
  • Notice 2026-61: Two-year extension of transition relief for dividend equivalents under section 871(m) regulations
  • U.S. Tax Court: BBA partnership petition deadline subject to equitable tolling
  • KPMG article: Potential permanent establishment, transfer pricing challenges associated with mobile workers
  • KPMG report: Transfer pricing and international tax year-end considerations

Read TaxNewsFlash-United States

  • President Trump signs into law Russia and Iran Sanctions Bill, which includes tariff authority
  • KPMG article: Comprehensive guide to digital asset tax legislation

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Belgium: Side-by-side package does not affect pending UTPR proceedings (Constitutional Court decision)
  • Netherlands: Transfer pricing documentation for taxpayer’s intercompany credit facilities found deficient (Court of Appeal decision)
  • Poland: Bill providing for simplification of transfer pricing reporting on intra-group transactions adopted by lower house of Parliament; other tax developments
  • UK: International controlled transactions schedule (ICTS) intended to apply beginning January 1, 2027
  • KPMG article: Potential permanent establishment, transfer pricing challenges associated with mobile workers
  • KPMG report: Transfer pricing and international tax year-end considerations

Read TaxNewsFlash-Transfer Pricing

FATCA / CRS / CARF

  • Channel Islands: Updated practical guide reflecting CRS XML schema v3.0 requirements (Jersey)
  • Isle of Man: Amended CARF regulations

Read TaxNewsFlash-FATCA / CRS / CARF

Trade & Customs

  • EU and Philippines reach “substantial agreement” on free trade
  • EU customs reform enters into force, with new e-commerce rules
  • KPMG report: New EU Customs Code enters into force; platforms face new obligations as “importer for distance sales”
  • President Trump signs into law Russia and Iran Sanctions Bill, which includes tariff authority
  • U.S. BIS identifies specialty pharmaceuticals eligible for 0% Section 232 tariff rate
  • U.S. BIS restricts stockpiling of polysilicon (solar) imports before Section 232 measures take effect
  • U.S. OFAC adds Sanctions Penalties Regulations

Read TradeNewsFlash-Trade & Customs

Africa

  • Kenya: Corporate sponsorship expenses not deductible, but tax authority’s allocation of expenses to exempt income disallowed (Tax Appeals Tribunal decision)
  • South Africa: Loan “raising fees” constituted deductible interest (Supreme Court of Appeal decision)

Read TaxNewsFlash-Africa

Americas

  • Canada: British Columbia pauses PST expansion to professional services
  • Central America and the Caribbean: Legislative, administrative, and judicial tax developments (August 2026)
  • Colombia: Temporary tax relief measures to mitigate impact of earthquake

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Draft guidance on cryptoassets
  • Bahrain: Updated VAT guides
  • Cambodia: Guidance on allocation of tax liabilities following, as well as VAT treatment of, business transfers, share transfers, and enterprise mergers
  • India: Concessional tax rate unavailable for interest on non-convertible debentures (tribunal decision)
  • India: Duration test for supervisory permanent establishment under Japan treaty must be applied on a project-by-project basis, not an employee-by-employee basis (tribunal decision)
  • India: Payments related to drugs manufactured and marketed in United States not taxable in India (High Court decision)
  • India: Unrealized foreign exchange gain arising from borrowings used to acquire property in India not taxable under section 43A, but may be taxable under section 43AA (tribunal decision)
  • New Zealand: “Bumper bill” advances 2026 budget reforms
  • Philippines: E-invoicing required by December 31, 2026
  • Uzbekistan: New VAT rules for nonresident e-commerce sellers

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Side-by-side package does not affect pending UTPR proceedings (Constitutional Court decision)
  • Cyprus: Guidance on VAT treatment of medical care
  • EU: Restriction on free movement of capital neutralized only when fund can obtain full relief under applicable treaty from discriminatory dividend taxation (CJEU judgment)
  • Germany: Updated general administrative regulation on tax audits; other tax developments
  • KPMG report: New EU Customs Code enters into force; platforms face new obligations as “importer for distance sales”
  • Malta: New site plan requirement for valuations of immovable property
  • Netherlands: Transfer pricing documentation for taxpayer’s intercompany credit facilities found deficient (Court of Appeal decision)
  • Poland: Bill providing for simplification of transfer pricing reporting on intra-group transactions adopted by lower house of Parliament; other tax developments
  • UK: Carbon border adjustment mechanism (CBAM) emissions regulations
  • UK: International controlled transactions schedule (ICTS) intended to apply beginning January 1, 2027
  • UK: Taxpayers must demonstrate scientific or technological advancement in R&D tax relief claims (First-tier Tribunal decision)

Read TaxNewsFlash-Europe

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