The KPMG Week in Tax for 5-9 October 2026 summarizes pivotal international tax developments. Highlights include progress on OECD Amount B (simplified baseline marketing/distribution pricing), IRS proposed regulations on the Corporate Alternative Minimum Tax (CAMT) under Section 55, UK secondary legislation laying the foundation for CBAM enforcement, and India’s new safe harbour rules for intra-group financing transactions. This edition is vital for transfer pricing, minimum tax, and cross-border compliance teams.
Key Takeaways
- Amount B Elective Application: The OECD released the final Amount B report, allowing jurisdictions to adopt a simplified pricing framework for baseline marketing and distribution activities. Over 30 jurisdictions have signaled intent to implement. Tax directors should map affected intercompany transactions and assess electing into Amount B vs. maintaining full TNMM documentation.
- US CAMT Regulations: The IRS issued proposed regulations clarifying adjusted financial statement income (AFSI) adjustments, foreign tax credit limitations, and the treatment of Pillar Two top-up taxes under CAMT. US-headed groups must model the interaction between CAMT (15% on AFSI) and GloBE Top-up Tax to avoid double minimum tax exposure.
- UK CBAM Enforcement Powers: The Customs (Carbon Border Adjustment Mechanism) Regulations 2026 (SI 2026/XXX) grant HMRC civil penalty powers for non-compliance, including failure to register, report, or surrender CBAM certificates. Importers must complete registration by 31 December 2026 to avoid automatic penalties from 1 January 2027.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
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