Nigeria Documentation-Deadline: On 3 October 2018, Federal Inland Revenue Service published a notice granting taxpayers that they have until 31 December 2018 to satisfy all pending obligations pertaining to filing of TP declaration, making disclosures of controlled transactions, submission of TP Documentation. Taxpayers will be subject to administrative penalties in case of any non-compliance with the obligations required by the set date of 31st December 2018.
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Dominican Republic Treaty Application: On 8 October 2018, the Dominican Republic had joined Inclusive Framework on BEPS developed by OECD. By becoming a member of this framework, the Dominican Republic has undertaken to incorporate into its laws and practices minimum standards agreed by countries in 2015 as a result of the OECD/G20 base erosion profit shifting (BEPS) project.
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Finland Restriction on interest deduction: According to proposal on 28 September 2018, the deductibility of net interest expense would remain same as current limited to 25% of EBITDA. The general deductibility threshold of EUR 500,000 would continue to apply and an additional threshold would be added under which the net interest expense of a third party would be fully deductible up to EUR 3 million.
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Zambia Audit Rules-Time limit: The time period for making transfer pricing assessment was increased by the 2019 budget presented to Parliament on 28 September 2018 for a period of 6 years but not more than 10 years.

Penalty for documentation failure: The penalty for non-compliance with the transfer pricing regulations has been revised from 10,000 penalty units (i.e. K3,000) to 80,000,000 million penalty units (i.e. K24,000,000).
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Ukraine BEPS related compliance: On 24 October 2018, government has published a draft law aimed at implementing some of key measures proposed under the OECD’s base erosion and profit shifting (BEPS) project. According to the announcement, the bill was drafted by a working group led by the Ministry of Finance with the participation of the NBU, and the participation and support of international tax experts. The new law is proposed to enter into force on 1 January 2020.
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Denmark Restriction on interest deduction: On 3 October 2018, the Danish Minister of Taxation submitted a bill to the parliament to transpose the EU Anti-Tax Avoidance Directives (ATAD 1 and ATAD 2) into Danish tax law. The bill retains the current rules that limit the deductibility of interest and other financing expenses with changes the EBIT rules substituted by EBITDA rule in accordance with the ATAD.
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Thailand Documentation-Thresholds: On 27 September 2018, Thailand’s National Legislative Assembly released the revisions to the draft Transfer Pricing Act (the draft TP Act). The revenue threshold for subject to transfer pricing documentation is THB200 million (US$6 million) per year (increased from THB30 million per year in original draft).The new transfer pricing act will be effective for accounting years starting on or after 1 January 2019.
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Norway Financial services-Restriction on interest deduction: The Norwegian Government proposes to change the rules on interest limitation in the fiscal budget 2019 published on 8 October 2018. The threshold for the interest expense deduction limitation rules to apply for companies within a group is proposed to be changed from NOK 5 million on an entity-by-entity basis to a total of NOK 25 million for all Norwegian companies within a group. The amended rules are proposed to apply as from the fiscal year ending in 2019.

Main corporate income tax rate: On 8 October 2018, the Norwegian Government published its proposal for the 2019 Fiscal Budget. The Government proposes the reduction in corporate tax rate from 23% to 22% in effect from January 1, 2019.
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Pakistan Documentation-Requirement: On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. The guidance requires companies to identify related parties and maintain records of transactions or contracts with these related parties which shall come into force on 1st January 2019.
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Australia MAP: On 29 October 2018, Australian Taxation Office (ATO) has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes. The new guidance represents an update on Taxation Ruling TR 2000/16 Income tax: international transfer pricing and profit reallocation adjustments, relief from double taxation and the Mutual Agreement Procedure, which has been withdrawn.
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El Salvador Specific TP compliance-Form: On 1 October 2018, the Tax Authority (General Office of Internal Revenue [DGII]) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and includes new technical requirements to be considered by taxpayers.
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Bulgaria Restriction on interest deduction: In accordance with the draft bill approved on 10 October 2018 by Council of Ministers, the restriction rule on interest deduction will be introduced under ATAD from 1 January 2019. The so called EBITDA rule (earnings before interest, taxes, depreciation and amortization) will apply for net borrowing costs exceeding €3m per year and limit their deduction at 30% of the taxable EBITDA.
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