Hong Kong: CbC reporting requirement: On 5 March 2018, Hong Kong government announced that it has launched its country-by-country reporting portal. Hong Kong Ultimate Parent Entities of Reportable Groups (HK UPEs) can now file CbC Returns for accounting periods beginning between 1 January 2016 and 31 December 2017 via the Portal voluntarily.
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Republic of Korea: BEPS related compliance-Penalty for non-compliance: Pursuant to revised enforcement decree of Korean tax laws promulgated on 13 February 2018, the penalties have been increased to KRW30 million (US$27,000) per documentation to file a combined report of cross-border transactions or file false information.
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Italy: Requirements-Control: On 21 February 2018, the Italian Ministry of Economy and Finance launched a public consultation of draft decree for transfer pricing provisions. The decree outlined certain issues including definition of ownership required to be considered “associated enterprises” (i.e., more than 50% ownership).
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Brazil: Intra-group services-General: Brazil has recently published Private Ruling 1001 of January 9 2018 regarding the deduction of certain cross-border payments to a foreign affiliate, including strategic decision support, information management, risk management and supply chain and acquisition management.
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Malaysia: Specific TP compliance-Form: The Malaysian tax office (MIRB) has recently updated the form used by the tax authority to gather information from certain taxpayers in connection with their cross-border transactions to conduct a transfer pricing risk assessment.
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Ukraine: Information Exchange: The Cabinet of Ministers of Ukraine has expanded the list of “low-tax” jurisdictions from 65 to 80 countries, adding 17 countries (Morocco, the United Arab Emirates and 15 others) and deleting two countries (French Guiana and Lesotho).
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India: APAs-Unilateral: India signed seven Advance Pricing Agreements (APAs) in February 2018. The total number of APAs now signed by India is 203, which includes 185 unilateral APAs. This current financial year, the CBDT has so far entered into 51 APAs, which includes 44 unilateral APAs.
APAs-Bilateral: India signed seven Advance Pricing Agreements (APAs) in February 2018. The total number of APAs now signed by India is 203, which includes 18 bilateral APAs. This current financial year, the CBDT has so far entered into 51 APAs, which includes 7 bilateral APAs.
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CbC reporting requirement-Parent company: On 14 March 2018, the lower house of the parliament (Lok Sabha) passed the Finance Bill 2018 with a few additional amendments to the CbC reporting and Master file requirements. Under this, the Indian constituent entity would now have an extension of time with regard to filing the CbC report domestically.
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APAs-Authority: Central Board of Direct Taxes (CBDT) has recently entered into an advance pricing agreement (APA) where the price determined by the Indian Customs authorities was accepted as arm’s length price for import transactions for transfer pricing purposes.
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Russia: Information exchange-Bilateral: The Government of the Russian Federation has published Decree No. 184 of 21 February 2018, which amends Decree No. 805 of 14 August 2014 on the conclusion of agreements for the exchange of information in tax matters.
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Colombia: Specific TP compliance-Form: Recently the Colombian tax authority (DIAN) has published a revised Form-120 to be filed in respect of the 2017 tax year. One of the major changes in Form 120 is adding a new section on the first page, notification – Country-by-Country (CbC) Report.
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Poland: Documentation-Deadlines: The ministry of Finance released a decree on 15 March, 2018 to extend the documentation deadlines to the end of the ninth month after the end of the fiscal year. The deadline for submission of special tax documentation for related party transactions as per Article 9a of CIT Act. and simplified transfer pricing statement as per Article 27(5) of the CIT Act. is extended to the end of the ninth month after the end of the fiscal year.
Master file: As per the decree released by the Ministry of Finance on 15 March 2018, the deadline for preparing Master file is extended to the end of the ninth month after the end of the fiscal year.
Local File: As per the decree released by the Ministry of Finance on 15 March 2018, the deadline for preparing Local file is extended to the end of the ninth month after the end of the fiscal year.
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Serbia: Financial Services: A “rulebook” of arm’s length interest rates for 2018 published in the Official Gazette of Serbia No. 18/2018 dated 9 March 2018. The Rulebook contains the prescribed interest rates applicable to taxpayers who had or will have related party financing during 2018. The Rulebook is effective as of 17 March 2018 and will be in force until 31 December 2018.
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Sweden: Treaty Application: Draft legislation was reportedly submitted to the Swedish parliament on 15 March 2018 for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which Sweden signed on 7 June 2017.
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Compliance-Main corporate income tax rate: On 21 March 2018, the Swedish Government submitted a draft bill to the Council on Legislation for their consideration. Accordingly, the existing corporate income tax rate of 22% will be reduced to 21.4% in 2019 and then further reduced to 20.6% in 2021.
Restriction on interest deduction: On 21 March 2018, the Swedish Government submitted a draft bill to the Council on Legislation that proposed a general limitation of interest deduction in the corporate sector with a maximum rate of 30% of EBITDA.
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Ireland: Intra-group services-Low value-adding services: On 15 March 2018, Irish Revenue released e-Brief No. 037/18 concerning guidelines on transfer pricing for low value intra-group services. The Guidelines describe the situations in which a cost-based methodology is determined to be the most appropriate transfer pricing method used to establish an arm’s length price for intra-group services of low value.
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Slovenia: Information exchange-Multilateral: On 22 March 2018, Slovenia became the fifth country to deposit its instrument of ratification for MLI to implement tax treaty related measures to prevent BEPS.  The MLI will enter into force once five countries have deposited instruments of ratification; Slovenia is the fifth country to deposit its instrument of ratification bringing the MLI into force.
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Argentina: CbC reporting requirement-Timing: With the publication of Resolution 4218 of 23 March 2018, the Argentine Tax Administration (AFIP) extended the deadline for taxpayers to comply with a notification requirement under the country-by-country (CbC) reporting regime. The new deadline ends on 2 May 2018.
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Singapore: CbC reporting requirement-General rule: According to Income Tax (International Tax Compliance Agreements) (Country-by-Country Reporting) Regulations 2018 published on 5 February 2018, two types of Multinational Enterprise (MNE) groups are required to submit a Country-by-Country (CbC) report to the Comptroller.
BEPS related compliance-Penalty for non-compliance: A fine of SGD 1,000 (US $ 760) will be imposed if the CbC report is not submitted by the due date or failure to retain all records for a five-year period to prepare a CbC report.
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Denmark: Making dispute resolution mechanisms more effective-Elements of minimum standards:
On 12 March 2018, the OECD published the third batch of peer review reports relating to the implementation of the BEPS minimum standard under Action 14 on improving tax dispute resolution mechanisms. As per the report, Denmark meets most of the elements of the Action 14 minimum standard.
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Norway: Making dispute resolution mechanisms more effective-Elements of minimum standards:
On 12 March 2018, the OECD published the third batch of peer review reports relating to the implementation of the BEPS minimum standard under Action 14 on improving tax dispute resolution mechanisms. As per the report, Norway meets most of the elements of the Action 14 minimum standard.
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Spain: Making dispute resolution mechanisms more effective-Elements of minimum standards:
On 12 March 2018, the OECD published the third batch of peer review reports relating to the implementation of the BEPS minimum standard under Action 14 on improving tax dispute resolution mechanisms. As per the report, Spain meets most of the elements of the Action 14 minimum standard.
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Indonesia: CbC reporting requirement-General rule: As per the guideline published on 26 March 2018, the ultimate parent entity of a MNE which is resident in Indonesia meeting a consolidated gross revenue threshold of IDR 11 trillion is required to submit CbC report. And if the ultimate parent is not resident in Indonesia, minimum threshold is EUR 750.
BEPS related compliance-Penalty for non-compliance:  As per the guideline published on 26 March 2018, the penalties for failing to comply with the CbC reporting and notification requirements, which include a fine up to IDR 1 million, as well as the possible triggering of a transfer pricing inspection that may result in additional penalties on adjustments.
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