US: Specific TP compliance: A specified national security contractor may submit an amended U.S. federal return and attach an amended Form 8975, prepared in accordance with Notice 2018-31, in order to supersede an already-filed Form 8975. To prevent the original CbC reports from being exchanged, any amended forms are to be filed by 20 April 2018-if filing on paper, or 25 May 2018-if filing electronically.
CbC reporting requirement-General rule: Pursuant to the Notice 2018-31 released on 30 March 2018, CbC reporting obligations for US MNE groups that qualify as a “specified national security contractor” limit the information required to be provided in Schedule A of Form 8975 so that all financial and employee information will be aggregated and reported only in the US.
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Advance Pricing Agreements: On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017.
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Restriction on interest deduction: On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017.
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Australia: Financial services-Restriction on interest deduction: On 4 April 2018, the Australian Taxation Office published the minimum interest rate for the simplified option for low-level outbound loans for the 2018 income year, which is set at 3.79%.
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Treaty Application: On 28 March 2018, the government submitted to Parliament Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 (the MLI Bill) as well as a detailed justification with useful guidelines on Australia’s MLI positions.
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UK: Treaty Application: On March 28, 2018, the UK issued a draft order to bring into effect the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which the UK signed on 7 June 2017.
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Zambia: Documentation-Thresholds: On 6 April 2018, Transfer Pricing (Amendment) Regulations 2018 is published under Statutory Instrument No. 24 of 2018. Under the Amendments, the threshold of ZMW 20 million (approximately $ 2.1 million) is not applicable to multinational enterprises (MNEs), effectively rendering all MNEs subject to transfer pricing requirements.
Documentation-Penalty for documentation failure: General penalty rules as per section 98 of the Income Tax Act may be applied. This may include a fine not exceeding 10,000 penalty units or imprisonment for a term not exceeding 12 months, or to both. The draft regulations provided for a penalty of ZMW500,000 (approx. US$50,000).
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Luxembourg: Coordination of Domestic and Cross-Border Dispute Resolution Procedures: On 20 March 2018, Luxembourg and France signed a new income tax treaty and a new protocol, replacing the current double tax treaty signed on 1 April 1958. The Treaty contains a number of treaty-based recommendations including BEPS action 14 (making dispute resolution mechanisms more effective).
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Hong Kong: Coordination of Domestic and Cross-Border Dispute Resolution Procedures: On 19 March 2018, Hong Kong and India signed a tax treaty which contains some treaty-based BEPS recommendations including Action 14 (making dispute resolution mechanisms more effective).
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BEPS related compliance: On 24 April 2018, the government published the first edition of Inland Revenue bill no.6 2017 to the BEPS Bill, which was adopted on 29 December 2017. The first set of amendments dealt with some of the key issues proposed by the business community, as well as professional persons in Hong Kong.
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Italy: Transfer pricing Legislation: On 5 April 2018, the Ministry of Economy and Finance published the responses received to the public consultation on transfer pricing legislation launched in February 2018.
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Belgium: Dispute resolution-Arbitration: On 7 March 2018, the Belgian tax authorities published Circular 2018/C/27 on the existing arrangements for the settlement of double taxation disputes arising from tax treaties.
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 Finland: Information exchange-Multilateral: On 6 April 2018, Parliament adopted a bill amending the relevant provisions of the Taxation Act in order to clarify the wording of the provisions of Council Directive (EU) 2016/881 of 25 May 2016 on administrative cooperation in the taxation of mandatory automatic exchange of information.
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Panama: Specific TP compliance-Form: On 9 April 2018, tax authority modified transfer pricing information return form by Resolution N° 201-1937 of 2 April 2018. The new form is Form No. 930 V2.0 (Form 930). Form 930 is effective from on 9 April 2018 and should be used to report the information corresponding to fiscal year 2018 and subsequent years.
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South Korea: Requirements-Rule: The South Korean National Tax Service has recently published a notice on certain changes, including in relation to the determination of the arm’s length price. In determining the arm’s length price, non-price transaction terms are also taken into account to improve the effectiveness of the transfer pricing method.
APAs-Rules: For tax years beginning before 1 January 2019, APA applications must be submitted with the relevant tax office no later than the end of the first taxable year in the specific period of taxable years to which the applicant intends to apply the method of computing an arm’s length price. For tax years beginning on or after 1 January 2019, APA applications must be submitted no later than the day before the first day of the first taxable year in the specific period of taxable years to which the applicant intends to apply the method of computing an arm’s length price.
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Indonesia: CbC reporting requirement: On 13 April 2018, tax authority has announced the launch of the electronic submission system for Country-by-Country reports via the DJP Online Portal.
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El Salvador: Comparability-Comparability analysis: On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing documentation.
Requirements-Control: The guidelines also outline the application of the transfer pricing rules for transactions with related parties and parties located in jurisdictions with preferential tax regimes or low or tax havens.
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Denmark: Documentation: On 28 March 2018, the Eastern High Court (Østre Landsret) issued a decision in favour of the taxpayer in a tax case on transfer pricing.  The high court also marked out the Danish statutory measure in relation to the date on which transfer pricing documentation has to be prepared, and the court’s decision has immediate compliance implications for companies operating in Denmark.
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Qatar: Information exchange-Multilateral: On 11 April 2018, the Cabinet approved the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The agreement will enable Qatar to implement international tax cooperation initiatives, including the automatic exchange of Country-by-Country (CbC) reports under the BEPS Action 13.
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France: Information exchange-Multilateral: On 19 April 2018, the Senate approved the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The Multilateral Instrument has been sent to the National Assembly for further approval. At the time of signature, France submitted its MLI position, listing its reservations and notifications and including 88 tax treaties that it wishes to be covered by the MLI.
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Canada: Adjustments-MAP: On 13 April 2018, the government of Canada updated its website to include its latest mutual agreement program (MAP) report. The CRA had 260 MAP cases on 1 January 2016. During 2016, the CRA accepted 124 new MAP cases and closed 160 MAP cases. The Canada Revenue Agency is updating its MAP guidance (IC71-17R5) and will issue an updated version of IC71-17R5.
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Serbia: Information exchange-Multilateral: On 19 April 2018, the National Assembly approved the law for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI).
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Greece: Information exchange-Multilateral: On 19 April 2018, Parliament passed a draft bill to ratify the agreement on exchange of country-by-country reports between Greece and United States. The agreement was signed on 27 September 2017.
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