Dominican Republic CbC reporting requirement-Threshold: On 22 June 2022, the Directorate General of Internal Revenue (DGII) published a Notice (No. 18-22) clarifying CbC for Multinational Enterprises (MNEs). If the group reports and is subject to the same threshold in its own jurisdiction, CbC reporting is not required in the Dominican Republic.
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Estonia Compliance with BEPS standards: On 1 June 2022, the OECD announced that the Republic of Estonia notified the confirmation of the completion of its internal procedures for the entry into effect of BEPS MLI.
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Greece Special rules for hybrid instruments or entities: On 30 June 2022, the government of Greece enacted legislation implementing ATAD’s reverse hybrid rule with retroactive effect from 1 January 2022. The hybrid entity will be considered a Greek tax resident and will be taxed on its income unless such income is otherwise taxed under the laws of Greece or any other jurisdiction.
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Hungary Comparability-Range: On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament. The bill proposes to revise the regulation of the application of the interquartile range.
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India MAP: On 10 June 2022, India’s Central Board of Direct Taxes (CBDT) issued comprehensive updated guidance on the Mutual Agreement Procedure (MAP) and related matters. The new guidance gives prominence to important aspects such as transparency in the disclosure of information that is material to the MAP process under tax treaty negotiations.
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Italy Comparability-Range: On 24 May 2022, the tax authority of Italy has issued Circular No. 16/E, that clarifies the application of the arm’s length principle (ALP) in transfer pricing. Specially, the Circular No. 16/E clarifies acceptable values within the arm’s length range.
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Netherlands Scope of transfer pricing rules: The Netherlands Tax and Customs Administration have published latest user guidelines for the use of the Mandatory Disclosure/DAC6 data portal for reporting potentially aggressive cross-border tax arrangements.
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Poland Filing deadlines: On 22 June 2022, the Polish Ministry of Finance has published a draft decree extending the deadline for submitting the CIT-8E return. Accordingly, the deadline for submitting the CIT-8E return is 30 September 2022.
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Transfer pricing information return: On 10 June 2022, the President of the Republic of Poland signed the Act of June 8, 2022 providing for the extension of the deadlines for submitting a declaration on the preparation of local transfer pricing documentation (TP statements) and TPR information in 2022.
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Transfer pricing information return: On 30 May 2022, the Treasury Department responded to a Parliamentary inquiry (No. 31287) regarding the rules for reporting transfer pricing information return (TPR-C form). The TPR-C form can be authenticated by a qualified electronic signature (certified by any EU state-designated entity).
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Qatar Documentation-Master/Local file: On 8 June 2022, the General Tax Authority (GTA) of Qatar issued Decision No. 10 of 2022 that amends the deadline for filing the transfer pricing Master File (MF) and Local File (LF). Accordingly, the amended due date for submission of the master and local file is 60 days after the due date for filing the corporate tax return.
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Romania Compliance with BEPS standards: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Romania on 1 June 2022.
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Spain Compliance with BEPS standards: On 1 June 2022, Spain submitted its notification confirming the completion of its internal procedures for the entry into force of the BEPS MLI.
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Digital economy transactions-General: On 23 May 2022, Spain published the Order HFP/480/2022 approving a revised form 490 of “Digital Services Tax (DST)”. The form replaces the previous form approved in Order HAC/590/2021 of 9 June 2021 with effect for self-assessments.
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Tanzania Digital economy transactions-General: On 14 June 2022, the Finance Minister presents the Budget for 2022/23 to the National Assembly. The budget introduces digital service tax at the rate of 2% on the turnover of the non-resident service providers.
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Ukraine Time limit and Statute of limitation: On 2 June 2022, the Ukrainian State Tax Service (STS) has published a notification that clarifies transfer pricing requirements under martial law conditions in Ukraine, taking into account of COVID-19 situation. The statute of limitations has been suspended from 15 March 2022 during the period of martial law due to the COVID-19 pandemic.
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