ChinaAPAs-Unilateral: On 26 July 2021, the State Administration of Taxation (SAT) issued Announcement No. 24 (2021) that finalizes a simplified procedure for unilateral advance pricing arrangements (APAs), which will come into effect on 1 September 2021.
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ColombiaCbC reporting requirement-General rule: On 11 August 2021, the Colombian National Tax Authority (DIAN) has issued Resolution No. 000072 setting out the procedure of the submission of the transfer pricing return and CbC notification for the tax year 2020 or part of the tax year 2021.
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Dominican RepublicCbC reporting requirement-General rule: On 3 August 2021, the Directorate General of Internal Revenue (DGII) opened a public consultation on a draft general standard concerning CbC reporting. The draft general standard provides templates for the CbC report in line with OECD guidelines. Comments are due on 7 September 2021.
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FinlandAdjustments: On 21 August 2021, the Finnish Ministry of Finance has launched a public consultation on draft bill concerning the revision of the Finnish transfer pricing adjustment provision. The proposed revisions will be applied from 1 January 2022.
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GermanyCbC reporting requirement-General rule: The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office’s newsletter, which updates the country-specific (CbC) reporting requirements based on Annual Tax Act 2020.
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Transfer pricing guidelines: On 14 July 2021, the Ministry of Finance (MoF) has issued new administrative principles on transfer pricing. The administrative principles include extensive references to the OECD Transfer Pricing Guidelines and provide further details clarifying the application of the OECD Guidelines.
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IsraelCbC reporting requirement-General rule: On 5 July 2021, the Israeli Ministry of Finance announced the approval of an amendment to the Transfer Pricing (TP) provisions of the Israeli Income Tax Ordinance (ITO). The amendment proposed to introduce the three-tiered TP documentation requirements developed as part of the OECD BEPS project.
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JordanCompliance with BEPS standards: On 11 August 2021, Jordan has deposited its instrument of ratification for the BEPS MLI. The Convention will enter into force for Jordan on 1 December 2021.
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KenyaDigital economy transactions-General: On 12 August 2021, the Kenya Revenue Authority published a release regarding the implications of the Finance Act 2021 on the Digital Service Tax (DST).
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LuxembourgCbC reporting requirement-General rule: On 20 August 2021, Luxembourg has announced that the section “Electronic exchange – country by country (CbC) reporting” as well as the frequently asked questions (FAQs) relating to the CbC declaration have been updated.
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Restriction on interest deduction: On 28 July 2021, the Luxembourg Tax Authorities has published Circular L.I.R. n° 168bis/1 (French), which clarifies certain aspects of the interest expense deduction limitation rules included in the article 168bis of the Luxembourg Income Tax Law (ITL).
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Poland Digital economy transactions-General: On 7 July 2021, a draft bill on digital services tax (DST) was submitted to Poland’s lower chamber of parliament (the Sejm). The bill includes a proposal of 7% tax on digital sector enterprises, regardless of their place of establishment, with a significant digital presence in the Poland.
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QatarFiling deadlines: On 30 August 2021, the General Tax Authority (GTA) of Qatar has announced an extension of submitting tax returns for fiscal year 2020 for companies and establishments owned by Qatari citizens and GCC citizens from 31 August 2021 to 31 December 2021.
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RomaniaCompliance with BEPS standards: On 19 August 2021, the Romania approved the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI).
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SingaporeCost contribution arrangements: On 10 August 2021, the Inland Revenue Authority of Singapore published the sixth edition of its E-Tax Guide on Transfer Pricing. The latest version provides significant updates and amendments to its previous 5th edition e-Tax Guide Transfer Pricing Guidelines including the guidance on how to prepare TPD, TP adjustment and a discussion on cost contribution arrangements (CCAs).
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Sri LankaTransfer pricing information return: On 16 August 2021, the Inland Revenue Department (IRD) of Sri Lanka published the transfer pricing disclosure form for the assessment year (AY) 2020/2021.
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ThailandFiling deadlines:  In response to Covid-19 pandemic, the Thai Ministry of Finance (MOF) has extended the deadlines for electronic filing of corporate income tax (CIT) to 23 September 2021 (generally due between 3 August 2021 and 22 September 2021).
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USInformation exchange-Multilateral: The Internal Revenue Service (IRS) published a joint statement with the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country reports for fiscal years beginning in 2020 and 2021.
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Information exchange-Multilateral: The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the Germany on the implementation of the spontaneous exchange of Country-by-Country Reports for fiscal years beginning in 2020.
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VietnamAPAs-General rule: On 3 August 2021, new detailed guidelines from the Vietnamese Ministry of Finance (MoF) on the Advance Pricing Agreement (APA) came into force. The guidance was published on 18 June 2021 and replace with the first circular on APAs (circular 201/2013 / TT-BTC) from 2013.
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