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KPMG Week in Tax: September 7 – 11, 2026

Recent tax developments from around the globe for the week of September 7 – 11, 2026

september 14, 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 implementing OBBBA changes to the section 250 and foreign tax credit rules include new limitations on allocating interest expense and research and experimental expenditures to section 951A category income. The proposed regulations also update the calculation of deduction eligible income (DEI) and provides guidance on which deductions may be reallocated to U.S.-source income for foreign tax credit limitation purposes, with the rules generally applying to tax years beginning after December 31, 2025. Read TaxNewsFlash
  • United States: President Trump signed five proclamations expanding trade actions against Canada under Section 338 of the Tariff Act of 1930, including import bans on certain Canadian alcoholic beverages, dairy products, and motor vehicle products, effective September 29, 2026. The proclamations also revise the scope of existing 50% duties on select Canadian products beginning September 15, 2026, with the White House noting that the measures apply in addition to Section 232 duties and regardless of USMCA eligibility. Read TradeNewsFlash
  • OECD: A new Pillar Two implementation package includes an updated GloBE Information Return (GIR), a framework for reviewing countries’ Pillar Two legislation, and additional administrative guidance. The guidance clarifies the treatment of certain taxes under the GloBE rules and confirms that the QDMTT safe harbor remains available in specified circumstances, while the updated GIR incorporates simplifications agreed to earlier in 2026 for filings covering fiscal years beginning on or after December 31, 2025. Read TaxNewsFlash
  • Belgium: The tax authorities have extended the filing deadline for Local file form submissions to November 10, 2026, for forms originally due September 30, 2026 (or November 3, 2026, for taxpayers with a March 31, 2026 year-end). The extension gives taxpayers additional time to comply with recent updates to the form and allows the authorities to implement a new electronic filing schema and updated XML filing tool expected by the end of September 2026. Read TaxNewsFlash

United States

  • Proposed regulations: Allocation and apportionment of deductions to foreign source section 951A category income and DEI
  • Proposed regulations: Qualified opportunity fund (QOF) reporting and certification procedures
  • U.S. Tax Court: Final partnership adjustment held timely under BBA limitations period rules
  • Notice 2026-53: 2026 emissions rates tables for section 45Z clean fuel production credit; guidance on use of manure-derived fuels and regenerative agricultural practices
  • Notices of filing of petitions for addition of four substances to Superfund list
  • IRS accepting applicants for 2027 CAP program beginning September 8
  • IRS announces tax relief for taxpayers in Hawaii and Oglala Sioux Tribe affected by natural disasters
  • KPMG article: 1% floor on charitable deductions may erode NOL carryovers
  • KPMG report: Automatic accounting method change procedures for R&E expenditures under Rev. Proc. 2026-32

Read TaxNewsFlash-United States

Transfer Pricing

  • Bahrain: Pillar Two guidance on computation of local DMTT
  • Belgium: Local file filing deadline extended to November 10, 2026
  • Belgium: Proposed legislation to transpose DAC9, amend minimum taxation rules
  • Italy: Tax measures in omnibus law, including implementation of Pillar Two side-by-side package
  • Malaysia: Recent tax developments concerning indirect tax, transfer pricing, and e-invoicing
  • OECD: Updated GloBE Information Return released as part of new Pillar Two implementation package
  • UAE: Pillar Two guidance on scope and registration requirements
  • United States: IRS accepting applicants for 2027 CAP program beginning September 8

Read TaxNewsFlash-Transfer Pricing

FATCA / CRS / CARF

  • Dominican Republic: Tax updates include FATCA relief, mandatory e-invoicing, and court decisions (August 2026)
  • Isle of Man: Advisory Notice on CRS XML schema v3.0 implementation timeline

Read TaxNewsFlash-FATCA / CRS / CARF

Trade & Customs

  • United States: Import bans and modified tariffs on Canadian alcoholic beverages, dairy, and motor vehicle-related products
  • Pakistan: Recent guidance on income tax, sales tax, and customs duties

Read TradeNewsFlash-Trade & Customs

Africa

  • Cote d’Ivoire: Temporary suspension of VAT on supplies used to manufacture fertilizers
  • Nigeria: Guidelines on taxation of virtual assets
  • UN: 2025 update to UN Model Tax Convention

Read TaxNewsFlash-Africa

Americas

  • Colombia: Introduction of national carbon market regulatory framework, including national carbon tax
  • Dominican Republic: Tax updates include FATCA relief, mandatory e-invoicing, and court decisions (August 2026)
  • UN: 2025 update to UN Model Tax Convention

Read TaxNewsFlash-Americas

Asia Pacific

  • Australia: Guidance on reintroduced loss carry back tax offset
  • Australia: Guidance on treatment of cross-border payments as royalties for withholding tax purposes; MoU with France on treaty arbitration process under MLI
  • Australia: Legislation amending foreign resident capital gain tax, merger control regimes passed by Parliament
  • Bahrain: Pillar Two guidance on computation of local DMTT
  • India: Consideration in excess of FMV received upon issuance of convertible debentures not taxable income (tribunal decision)
  • India: One-time compensation received for diminution in value of stock options not taxable employment income (tribunal decision)
  • Lebanon: New implementation rules for exceptional (Sayrafa) tax
  • Malaysia: Recent tax developments concerning indirect tax, transfer pricing, and e-invoicing
  • Pakistan: Recent guidance on income tax, sales tax, and customs duties
  • Philippines: Updated guidelines for tax audit program
  • UAE: Pillar Two guidance on scope and registration requirements
  • UN: 2025 update to UN Model Tax Convention

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Local file filing deadline extended to November 10, 2026
  • Belgium: Proposed legislation to transpose DAC9, amend minimum taxation rules
  • Czech Republic: Draft legislation implementing aspects of ViDA package passed by lower house of Parliament
  • Denmark: Updated dividend withholding tax refund procedure
  • EU: CJEU referral on implementation of ATAD interest limitation rules (Belgium)
  • EU: Public consultation on alignment of VAT rules with circular economy
  • Germany: Application of minimum taxation rules resulting in permanent loss of tax loss carryforwards upheld (Federal Fiscal Court decision)
  • Greece: List of jurisdictions with preferential tax regimes for 2024 tax year
  • Italy: Tax measures in omnibus law, including implementation of Pillar Two side-by-side package
  • Lithuania: Updated guidance on CFC and thin capitalization rules
  • Poland: Proposed temporary corporate tax rate increase for energy and fuel sectors; other tax developments
  • Romania: "TechUp Romania" scheme enacted
  • San Marino: E-invoicing mandate for domestic transactions effective January 1, 2027
  • Serbia: Amendments to corporate income tax law
  • Serbia: Amendments to rules on temporary reductions and increases in excise duty amounts on oil derivatives
  • Serbia: Prohibition on performing activities for one year in cases of invalid QR codes on receipts
  • UK: Property developer profits taxable in UK under Article 6 of Isle of Man income tax treaty (Upper Tribunal decision)
  • UN: 2025 update to UN Model Tax Convention

Read TaxNewsFlash-Europe

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