ArgentinaTransfer pricing information return: On 18 June 2021, the Federal Administration of Public Revenues (AFIP) officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms for tax years ended between 31 December 2020 and 31 December 2021.
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CanadaMAP: On 1 June 2021, the Canada Revenue Agency (CRA) published an Information Circular IC71-17R6 regarding Mutual Agreement Procedures which replaces and cancels the Information Circular 71-17R5 released on 1 January 2005.
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CroatiaCompliance with BEPS standards: According to OECD publication on 29 June 2021 regarding the BEPS (MLI), the convention entered into force for Croatia on 1 June 2021. Croatia was signed the convention on 7 June 2017 and was deposited its instrument on 18 February 2021.
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CyprusScope of transfer pricing rules: On 3 June 2021, the Cyprus tax department has issued a notice providing an extension to the imposition of administrative fines for overdue submission of DAC6 reporting until the 30th September 2021.
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JordanScope of transfer pricing rules: On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 introducing transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021.
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LuxembourgRestriction on interest deduction: On 2 June 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis, which clarifies certain aspects of the interest expense deduction limitation. The tax deduction for interest and other borrowing costs is limited to 30% of earnings before interest, taxes, depreciation, and amortization (EBITDA) or EUR 3 million.
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Malaysia Compliance with BEPS standards: According to OECD publication on 29 June 2021 regarding the BEPS (MLI), the convention entered into force for Malaysia on 1 June 2021.
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CbC reporting requirement-Deadline: On 25 May 2021, the Inland Revenue Board of Malaysia announced on its website that starting from the year of assessment (YA) 2021, constituent entities can now furnish the Country-by-Country Reporting (CbCR) Notification using the C Form.
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MoroccoMAP: The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes.
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PortugalDocumentation-Timing and deadlines: According to the Order No. 191/2021-XXII of 15 June 2021, Portugal has extended the deadline for the preparation of transfer pricing (TP) documentation (and submission if required) to 22 July 2021 (usually by 15 July).
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QatarMaster File-Local File-Deadlines: On 17 June 2021, the General Tax Authority (GTA) of Qatar published Decision No. 8 of 2021 extending the deadline for submission of the Master file and Local file from 30 June 2021 to 30 September 2021 for the 2020 fiscal year.
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SingaporeAdjustments-Primary adjustment: On 1 June 2021, the Inland Revenue Authority of Singapore (IRAS) has published second edition of e-Tax Guide GST-Transfer Pricing Adjustments. The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between related parties.
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SpainDigital economy transactions-General: On 11 June 2021, Spain published the form 490 for the digital services tax that was approved on 9 June 2021. The new form will only be available in electronic form and must be submitted electronically.
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MAP: On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008.
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UAEMAP: The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes.
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VietnamAPAs-General rules: On 18 June 2021, the Vietnamese Ministry of Finance (MoF) has issued Circular 45/2021/TT-BTC, which sets out new rules on Advance Pricing Agreements in Vietnam. The Circular takes effect from 3 August 2021, replacing Circular No. 201/2013/TT-BTC dated 20 December 2013 of the Ministry of Finance.
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