DenmarkDocumentation-Deadlines: On 6 November 2019, the Danish Minister of Taxation published Bill no. L 48 on international taxation. Accordingly, transfer pricing documentation must be submitted to the tax authorities no later than 60 days after the deadline for the filing of the annual corporate income tax return.
Penalty for documentation failure: Transfer pricing penalties may be imposed if the TP documentation is not submitted within the 60-day deadline. Daily penalties may be imposed if the TP documentation is not submitted within the 60-day deadline.
Audit Rules-Burden of proof: The tax authorities will be entitled to assess a taxpayer on an estimated basis for TP purposes if the TP documentation is not contemporaneous and is not submitted within the 60-day deadline, i.e. the burden of proof is reversed.
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Requirements-Rule: On 6 November 2019, the Danish Minister of Taxation published bill no. L 49 on implementation of Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on reportable cross-border tax planning arrangements (DAC6).
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KenyaTreaty Application: On 26 November 2019, Kenya signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
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OmanTreaty Application: On 26 November 2019, Oman signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
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LatviaDispute resolution: On 22 October 2019, the Law of 17 October 2019 on amendments to the Law on Taxes and Duties has been published in the Latvian official gazette, which provides for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017. The law includes provisions to ensure effective resolution of disputes over the interpretation and application of bilateral tax treaties.
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USCbC reporting requirement-General rule: On 6 November 2019, the US Internal Revenue Service (IRS) published a notice requesting comments concerning IRS Form 8975 regarding CbC report. Written comments should be received on or before January 6, 2020 to be assured of consideration.
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BulgariaDocumentation-Thresholds: On 21 November 2019, the Bulgarian parliament approved amendments to the thresholds for mandatory preparation of a local transfer pricing documentation. According to the amendments, the obligation to prepare such documents from 1 January 2020 will not apply if it doesn’t meet specific thresholds.
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Requirements-Rule: On 14 November 2019, the National Assembly (NA) accepted for consideration a draft bill to transpose an EU directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6).
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SwedenRequirements-Rule: On 25 October 2019, the Swedish Tax Agency issued a guidance on the implementation of an EU Council Directive on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6).
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IndiaMain corporate income tax rate: On 25 November 2019, the Finance minister presented the Taxation Laws (Amendment) Bill, 2019 in the lower house of Parliament (Lok Sabha).  The bill proposed to provide an option for a concessional tax at the rate of 22 per cent in the case of a domestic company subject to certain conditions.
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Czech RepublicAdjustments-Treaty Application: On 28 November 2019, the Chamber of Deputies approved the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI).
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Costa RicaAdjustments-Treaty Application: On 12 November 2019, Costa Rica enacted Law No. 9751 by publishing the official gazette No.215. The law ratifies the Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI).
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Documentation requirement-Master/Local File: On 13 November 2019, the Costa Rican tax authority released a Resolution No.DGT-R-49-2019 providing new guidelines on transfer pricing documentation including master file and local file.
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TaiwanAdjustments-Primary adjustment: On 15 November 2019, the Ministry of Finance issued a ruling no.10804629000 providing the guidance when multinational enterprises (MNEs) make a one-time transfer pricing adjustment to achieve an arm’s length result.
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EstoniaSpecial rules for hybrid instruments or entities: On 18 November 2019, Estonian Parliament passed EU Anti-Tax Avoidance Directive (2017/952) (ATAD 2) into Estonian domestic law in its first reading.
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PolandDispute resolution: On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019.
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South AfricaInformation exchange-Multilateral: On 1 November 2019, the South African Revenue Service (SARS) has published an updated list of jurisdictions with that have effective CbC report exchange agreements as of 18 October 2019.
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AustraliaDocumentation requirement-Master File/Local File/CbC reporting: The Australian tax authority has allowed “significant global entities” time until 31 December 2019 to lodge their master file, local file and country-by-country (CbC) reports.
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CroatiaRequirements-Rule: On 31st October 2019, the Government published a bill regarding the implementation of mandatory disclosure rules pursuant to the EU’s Council Directive 2018/822 of 25 May 2018 (commonly referred to as DAC6) into Croatian’s domestic law.
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SerbiaCbC reporting requirement-General rule: On 18 October 2019, the Serbian parliament accepted for consideration a bill to implement country-by-country (CbC) reporting obligations for multinational entities (MNEs). The obligation to prepare the CbC report will come into force from 2020.
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AustriaRequirements-Rule: On 22 October 2019, the government of Austria officially published the EU-Mandatory Disclosure Act implementing the European Union (EU) Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). Under DAC6, taxpayers and intermediaries are required to report cross-border reportable arrangements from 1 July 2020.
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IrelandRequirements-Rule: On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6) to the Ireland’s legislature.
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Bosnia and HerzegovinaTreaty Application: On 30 October 2019, Bosnia and Herzegovina signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI).
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