Attached is EY’s update on PE developments, including COVID-19 situations and implementation of multilateral instruments (MLIs).
India’s summary is interesting, being known for aggressive PE and mark-up percentages, as it was determined that remuneration was arm’s-length, thus the PE issue was irrelevant.
https://www.ey.com/en_gl/tax-alerts/pe-watch-latest-developments-and-trends-november-2020
Strategizing Multinational Tax Risks 
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