Australia Local file-General rule: On 9 August 2022, the Australian Taxation Office (ATO) updated guidance on the Local and Master file for 2022 along with instructions. The guidance applies to reporting periods beginning on or after 1 January 2021.
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Bulgaria Compliance with BEPS standards: On 17 June 2022, Bulgaria ratified the OECD Multilateral Convention (MLI) (2017) and published it in the Official Gazette (No. Decree No. 153).
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France Transfer pricing case: Recently, the French Court of Appeal of Paris issued a decision in the case of France v. Ferragamo France (No. 20PA0360), in June 2022, explaining the transfer pricing (TP) rules for cross-border group companies.
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Hungary Scope of transfer pricing rules: On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) which contains the amendments for transfer pricing rules.
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Ireland Digital economy transactions-General: On 8 August 2022, the Irish Revenue published an eBrief No. 158/22 on Tax and Duty Manual Part 04-06-03 providing guidance on the tax deductibility of Digital Services Taxes (DSTs).
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Lithuania Scope of transfer pricing rules: On 12 August 2022, the Lithuanian Parliament accepted a bill relating to the VAT registration threshold for related persons. Under this, when related persons carry out economic activity, they would be given a right to prove that there is no artificial business division and, as a result, they are not subject to oblige VAT registration.
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Russia CbC reporting requirement-General rule: Recently, the Federal Tax Service of Russia published (Order No. ED-7-17/449) a new list of foreign states (territories), with which Russia will automatically exchange Country-by-Country (CbC) reports.
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Singapore CbC reporting requirement-Deadlines: On 11 August 2022, the Ministry of Finance published an amended Regulation No. S 669 on Country-by-Country (CbC) Reporting Agreements. Accordingly, certain companies are required to file CbC reports with the Comptroller or an authorized person for each accounting period beginning on or after 1 January 2022.
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Primary adjustment: On 3 August 2022, the IRAS updated the GST-E Tax Guide on Transfer Pricing Adjustments (Third Edition). The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions between related parties and is relevant when taxpayers have TP adjustments made to their transactions with related parties.
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Slovak Republic Restriction on interest deduction: The government of the Slovak Republic has approved the draft law amending transfer pricing rules including implementation of rules on restriction of interest deduction in accordance with the EU Anti-tax Avoidance Directive (ATAD).
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Ukraine Transfer pricing information return: On 17 August 2022, the Ukrainian State Tax Service (STS) announced that the deadline for submitting transfer pricing (TP) reports on controlled operations and notifications on participation in the international group of companies for the reporting year 2021 is 30 September 2022.
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US Transfer pricing case: On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner.
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Transfer pricing case: On 18 August 2022, the U.S. Tax Court issued an opinion on the transfer pricing case of Medtronic, Inc. v. Commissioner, T.C.  Memo 2022-85. In this opinion, the Tax Court rejected the principal transfer pricing analysis of both the Internal Revenue Service (IRS) and Medtronic Inc. (Medtronic US), and instead applied an unspecified methodology.
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