AustriaScope of transfer pricing rules: On 21 October 2020, the Finance Ministry published final guidance of cross border arrangements (DAC6) including definition of terms, reportable arrangements, hallmarks and main benefit test, deadlines for reporting, etc.
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BelarusInformation exchange-Multilateral: On 14 October 2020, Belarus has published Resolution No. 590 on the National Legal Internet Portal, through which Belarus is set to join the Global Forum on Transparency and Exchange of Information for Tax Purposes.
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BelgiumCompliance-Filing deadlines: On 12 October 2020, the Ministry of Finance declared further extension of the deadline for filing corporate income tax (CIT) return to 16 November 2020 for Assessment Year 2020.
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ColombiaMAP: On 21 August 2020, the Colombian National Tax Authority has issued Resolution No. 000085 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and prevent evasion in Colombia.
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Costa RicaRestriction on interest deduction: On 15 October 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense.
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Czech RepublicDigital economy transactions-General: The Government decided to introduce a domestic digital service tax. Companies with a global turnover of EUR 750 million, including on turnover from digital advertising, the sale of user data, and intermediation services are subject to 7% DST rate.
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EgyptMaster file/Local file-Threshold: On 19 October 2020, Egyptian approved a unified tax procedures law (Law no. 206 of 2020). The Law stipulates that the taxpayers must prepare and submit Master file and Local file if their total related party transactions exceed EGP 8 million during a tax period.
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FranceDigital economy transactions-General: France intends to collect the country’s digital services tax in December 2020, which was due in April and October 2020.
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Hong KongCbC reporting requirement-General rule: On 6 October 2020, Inland Revenue Department of Hong Kong has published the updated CbC reports XML schema and user guide. From 1 February 2021, data files must be prepared using CbC Return XML Schema (version 2.0). Up to 31 January 2021, data files must be prepared using CbC Return XML Schema (version 1.0).
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IndiaCompliance-Filing deadlines: On 24 October 2020, the Indian Finance Ministry published a notice regarding further extension of due date for furnishing of Income Tax Returns for the taxpayers who are required to furnish report in respect of international/specified domestic transactions to 31st January, 2021.
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Comparability-Range: On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21.
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IndonesiaAPAs-General rules: On 17 September 2020, the Indonesian Directorate General of Taxation published a Regulation No. PER- 17/PJ/2020 regarding the procedures for completing applications, implementing, and evaluating an advance pricing agreement (APA).
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IrelandRestriction on interest deduction: Ireland has a plan to consult with stakeholders in 2021 with the intent to enact ATAD-compliant interest limitation rules in Finance Bill 2021, taking effect from 1 January 2022. The rule limits current period tax deductions for related party interest up to 30% of taxable EBITDA.
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IsraelDocumentation-CbC reporting requirement: On 12 October 2020, the Israeli Tax Authority (ITA) published a draft bill for public consultation proposing to incorporates the principles of the OECD’s BEPS Action 13.
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ItalyCbC reporting requirement-General rule: The Italian tax authorities updated the technical rules and filing instructions to submit country-by-country (CbC) reports in accordance with the OECD’s CbC XML schema adopted in June 2019.
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JordanCompliance with BEPS standards: On 29 September 2020, Jordan deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) with the OECD.
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LuxembourgScope of transfer pricing rules: On 14 October 2020, the Luxembourg Tax Administration has issued updated guidelines concerning the mandatory disclosure and exchange of cross-border tax arrangements (DAC6) as per Council Directive (EU) 2018/822 of 25 May 2018.
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PeruInformation exchange-Multilateral: On 21 October 2020, the Peruvian tax authorities has announced that they will start the CRS Multilateral Competent Authority Agreement (CRS MCAA) with more than 130 countries beginning in 2021.
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CbC reporting requirement-Deadlines: On 25 September 2020, the Peruvian tax authority released a Resolution No. 000155-2020/SUNAT extending the deadline to submit the 2019 country-by-country (CbC) reports for specific entities.
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South KoreaMAP: On 20 October 2020, South Korea’s National Tax Service (NTS) has released updated Mutual Agreement Procedure (MAP) guidance on the official website.
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SpainDigital economy transactions-General: On 16 October 2020, the Spanish Official Gazette published the Laws Nos. 4/2020 and 5/2020, implementing a digital services tax and a financial transactions tax.
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Sri LankaTransfer pricing information return: The Inland Revenue Department (IRD) has published the transfer pricing (TP) disclosure form and guide for the assessment year (AY) 2019/2020. Taxpayers are required to complete this form if they have conducted controlled transactions with related parties equal to or more than LKR 200 million during the year.
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USAPAs-General rules: On 28 October 2020, the Internal Revenue Service (IRS) is updating parameters that the Advance Pricing and Mutual Agreement program (APMA) officials has to be followed in implementing MAP/APA resolutions negotiated under US tax treaties.
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ZambiaDocumentation-Thresholds: On 25 September 2020, the Minister of Finance (MOF) presented the budget for 2020 to the National Assembly. The budget includes the proposal to increase the threshold to ZMW 50 million from ZMW 20 million for local companies that are not required to provide transfer pricing documentation.
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