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KPMG Week in Tax: September 28 – October 2, 2026

Recent tax developments from around the globe for the week of September 28 – October 2, 2026

October 5, 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 IRS and Treasury issued guidance targeting investment fund strategies that may produce tax results inconsistent with federal tax rules. The guidance addresses certain ETF transactions, including transfers of appreciated securities, as well as other “tax-aware” fund strategies, and signals that additional guidance or enforcement action may follow. Read TaxNewsFlash
  • United States and China: The United States and China established a bilateral trade framework under which each country will consider approximately $30 billion of imported goods for potential reduced tariff treatment. The framework also addresses agricultural market access, U.S. coal exports to China, and critical mineral supply chains. Read TradeNewsFlash
  • Norway: The tax authority issued final regulations introducing phased mandatory e-invoicing and digital accounting requirements. E-invoicing for certain domestic B2B sales begins January 1, 2027, with broader e-invoicing receipt and electronic accounting system requirements taking effect January 1, 2030. Read TaxNewsFlash
  • Costa Rica: The Executive Branch submitted two tax bills that would expand the taxation of foreign-source passive income (read TaxNewsFlash) and establish a new framework for tax incentives (read TaxNewsFlash). The proposals would broaden the taxpayers subject to tax on foreign passive income and strengthen the administration and oversight of tax incentives while retaining certain specified exemptions and benefits. 

United States

  • Temporary and proposed regulations: Guidance on new individual tax credit under section 25F for gifts to scholarship granting organizations
  • Temporary and proposed regulations: Guidance regarding establishment of initial Trump account and qualified general contributions, including qualified stock contributions
  • Proposed regulations: Election under new section 1062 to pay tax on gain from certain farmland property in installments
  • IRS Priority Guidance Plan for 2026-2027
  • Notice 2026-58: 71 additional items of IRB guidance obsoleted in accordance with Executive Order 14219
  • Notice 2026-63: Tax relief for taxpayers affected by terroristic action in Israel
  • Notice of filing of petition for addition of one substance to Superfund list
  • Rev. Rul. 2026-20 and Notice 2026-62: Potentially abusive transactions involving investment funds
  • U.S. Tax Court: Form 872-T does not terminate a fixed-date consent to extend assessment period under Form 872
  • California: Legislation retroactively decouples from IRC section 163(j) for individuals and non-corporate entities

Read TaxNewsFlash-United States

  • Senate passes bipartisan tax administration reform package

Read TaxNewsFlash-Legislative Updates

Transfer Pricing

  • Argentina: Restructured transfer pricing regime
  • Belgium: Income tax and Pillar Two filing deadlines extended
  • Germany: Challenge to legality of the German Minimum Tax Act dismissed (Cologne Fiscal Court decision)
  • Nigeria: Guidance on new corporate income tax rules, including 15% minimum tax
  • Portugal: Extension of Pillar Two registration deadline

Read TaxNewsFlash-Transfer Pricing

FATCA / CRS / CARF

  • Finland: Transition to new CRS/DAC2 reporting schema
  • Germany: Transition to CRS XML schema v3.0
  • Liechtenstein: Restoration of CRS and FATCA reporting portals
  • Uruguay: CRS reporting deadline moved forward

Read TaxNewsFlash-FATCA / CRS / CARF

Trade & Customs

  • U.S. BIS renews denial of export privileges for Russian airline
  • U.S. CBP issues withhold release orders on Indonesian palm oil imports over forced labor
  • U.S. OFAC amends, issues regulations implementing Cuba sanctions policy
  • U.S. State Department proposes changes to U.S. Munitions List and ITAR license exemption
  • U.S. State Department revises ITAR policy for Syria
  • United States and China establish trade framework, identify $30 billion in goods for potential tariff reductions

Read TradeNewsFlash-Trade & Customs

Africa

  • Africa: Overview of recent tax developments (September 2026)
  • Nigeria: Guidance on new corporate income tax rules, including 15% minimum tax
  • Tunisia: Updated list of jurisdictions with preferential tax regimes
  • KPMG article: How countries govern international tax under the UN framework

Read TaxNewsFlash-Africa

Americas

  • Argentina: Restructured transfer pricing regime
  • Chile: Tax treatment of corporate reorganization involving capital contribution followed by redemption; other tax developments
  • Colombia: Temporary tax incentives to support investment in earthquake-affected regions
  • Costa Rica: Bill proposing new tax incentive regime and tax expenditure controls submitted to Parliament
  • Costa Rica: Bill proposing to change taxation of foreign-source passive income submitted to Parliament
  • KPMG article: How countries govern international tax under the UN framework

Read TaxNewsFlash-Americas

Asia Pacific

  • India: Performance of liaison and support functions did not create PE in India under Swiss treaty (tribunal decision)
  • India: Subscription fees for digital content did not constitute fees for technical services (Supreme Court decision); other direct and indirect tax developments
  • KPMG article: How countries govern international tax under the UN framework
  • Sri Lanka: TIN certificate required for specified transactions beginning November 1, 2026

Read TaxNewsFlash-Asia Pacific

Europe

  • Belgium: Income tax and Pillar Two filing deadlines extended
  • Estonia: Retroactive registration of VAT taxable person upheld; prior communications did not rise to level of an audit (Circuit Court decisions)
  • EU: CJEU referral on compatibility of payroll tax with parent-subsidiary directive (France)
  • EU: Public consultation on omnibus proposal to simplify EU rules on direct taxation
  • Germany: Challenge to legality of the German Minimum Tax Act dismissed (Cologne Fiscal Court decision)
  • KPMG article: How countries govern international tax under the UN framework
  • Malta: Amendments to gaming tax framework
  • Netherlands: Guidance on substance requirements for dividend withholding tax exemption
  • Netherlands: Proposal to replace Box 3 (“wealth tax”) regime with capital gains tax on all assets
  • Netherlands: Sustainability-related tax developments (September 2026)
  • Norway: Final regulations for digital reporting and e-invoicing mandate
  • Poland: Absence of accounting depreciation does not preclude tax depreciation (Supreme Administrative Court decision); other tax developments
  • Poland: Reserved alternative investment fund entitled to refund of withholding tax on dividends (Supreme Administrative Court decision)
  • Portugal: Extension of Pillar Two registration deadline
  • Serbia: Amendments to e-invoicing adopted by Parliament
  • Serbia: Amendments to tax procedure and administrative law adopted by Parliament

Read TaxNewsFlash-Europe

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