ArgentinaTransfer pricing information return: On 30 April 2021, the Federal Administration of Public Revenue (AFIP) made an announcement that it will exceptionally extend the due date of submitting transfer pricing study and Form F. 2668 from June 2021 to September 2021.
See the story in Regfollower
EstoniaCompliance with BEPS standards: On 1 May 2021, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Estonia.
See the story in Regfollower 
GreeceInformation exchange-Multilateral: On 22 April 2021, the Public Revenue Authority (AADE) published Circular A.1092 of 22 April 2021, which determines the lists of jurisdictions with which Greece wants implement the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbC) Reports based on Law 4490/2017 for data of the tax year 2019.
See the story in Regfollower
HungaryFiling deadlines: On 21 April 2021, the Finance Ministry of Hungary published a Decree extending filing deadlines for all major business income tax returns due to COVID-19. Accordingly, annual returns for corporate income tax, local business tax, and energy suppliers’ income tax will be due September 30 rather than May 31.
See the story in Regfollower
IndiaDigital economy transactions-General: On 3 May 2021, the Central Board of Direct Taxes (CBDT) issued a Notification No.40/2021 which sets the revenue and user thresholds for the application of a new nexus rule for nonresidents in the form of “significant economic presence” (SEP) in India.
See the story in Regfollower
KenyaRelated party definition: On 5 May 2021, the Parliament of Kenya has published the finance bill 2021 providing the new the definition of the term ‘‘Control”. Control currently means that a person owns at least 25% of the shares or voting rights. The bill proposes to reduce this to 20%.
CbCR requirement: The bill proposes CbCR to be enacted in line with the requirements of the members of the OECD / G20 Inclusive Framework on BEPS.
Corporate residence: The bill proposes to repeal the current definition of “permanent establishment” (PE) and introducing a new definition that adapts to the international best practices of the OECD and UN model tax treaties as well as the BEPS project.
Digital economy transactions-General: The bill extends the scope of DST to all income generated by businesses over the Internet or electronic networks. This is a deliberate attempt to broaden the tax base of the digital economy.
Restriction on interest deduction: The bill aims to tighten the thin capitalization requirement from a simple 3: 1 ratio to 30% of EBITDA, thereby capping all borrowing expenses. Interest paid or payable to related parties and third parties is limited to 30% of earnings before interest, taxes, depreciation and amortization (EBITD).
See the story in Regfollower
MaltaPenalties for documentation failure: Recently, Malta has issued Regulations (L.N. 213 of 2021) named ‘Cooperation with Other Jurisdictions on Tax Matters’. The Regulation has introduced penalties for non-compliance with Maltese CbCr obligations of €200 and €50 for every day of non-compliance to each stated obligation separately. But this penalty shall not exceed in total five thousand euro (€5,000).
See the story in Regfollower 
NigeriaCbC reporting requirement-General rule: The Federal Inland Revenue service (FIRS) issued a public notice to suspend the CbC reporting obligations for MNE branches under the Regulation 4 of the “Income Tax (CbC Regulations) Regulations, 2018”.
See the story in Regfollower 
ParaguayApplication-Other methods: On 16 April 2021, the tax authority of Paraguay has published General Resolution No. 86 with effect from 17 April 2021, regarding the application of the special transfer pricing (TP) rules, related to the sixth method, for certain commodity transactions, i.e. rice, soy products, corn, wheat, etc.
See the story in Regfollower  
PeruComparability analysis: On 29 April 2021, the Peruvian tax authorities (SUNAT) has issued Administrative Guidance No. 036-2021-SUNAT/7T0000 providing guidance in relation to use of multi-year data in determining arm’s length transfer pricing.
See the story in Regfollower 
PolandDocumentation-Timing and deadlines: On 19 April 2021, the Polish tax authority announced an extension of the transfer pricing documentation deadlines. Accordingly, the deadline for submitting information on transfer pricing by 30 September 2021 – if this period expires in the period from 1 February 2021 to 30 June 2021, and by 3 months – if this period expires in the period from 1 July 2021 to 31 December 2021.
See the story in Regfollower 
QatarDocumentation-Master/Local file: Qatar’s General Tax Authority (GTA) has issued frequently asked questions (FAQs) regarding Transfer Pricing Declaration, Master File, and Local File on the Dhareeba tax portal. The FAQs provide clarification on several tax issues relating to transfer pricing (TP) compliance and documentation requirements.
See the story in Regfollower
ThailandFiling deadlines: On 30 April 2021, the Thai Ministry of Finance announced an extension of the deadline for filing the annual corporate income tax return (PND.50) and for paying the related tax to 30 June 2021 from May 2021 in response to the Covid-19 pandemic.
See the story in Regfollower