Malaysia: APAs-Fees: In December 2017, APA rules 2012 was amended by inserting a new Rule 23 which allows the MIRB to charge an application fee and any expenses as the Director General may determine in the course of the APA application. The APA Rules 2017 came into operation on 1 January 2018.
Adjustments-MAP:  The MIRB has recently released the updated Mutual Agreement Procedure (“MAP”) Guidelines which were first announced in January 2015. The update to the MAP guidelines is intended to align the MAP guidelines in line with the OECD’s BEPS action 14, which would allow the Malaysian competent authority to cooperate with CAs of treaty-partner countries with a view to solving certain tax issues.
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Costa Rica: CbC reporting requirement-General rule: On 2 February 2018, Costa Rica published the Resolution no.DGT-R-001-2018. Resolution No.DGT-R-001-2018 requires multinationals to submit a CbC report in accordance with the OECD’s recommendations for the erosion and profit shifting base (BEPS) Action 13.
CbC reporting requirement-Timing: The first CbC report must be made by December 31, 2018, at the latest, relating to the 2017 fiscal year. The same schedule applies to future years. The CbC report is required by December 31 of each year following the relevant fiscal period.
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India: Main corporate income tax rate: The Minister of Finance introduced the Union Budget 2018-19on 1 February 2018. The budget would extend the benefit of a concessional corporate tax rate of 25% to domestic companies with a turnover of up to ceiling INR 250 crore in the Fiscal Year 2017.
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CbC reporting requirement-Timing: On 1 February 2018, the Finance Minister presented the Union Budget 2018 including a proposal to extend the due date for furnishing the CbC report, 12 months from the end of the reporting accounting year. The due date would therefore vary for each situation depending on the taxpayer’s accounting year. For FY 2016-17, the due date has already been extended to 31 March 2018.
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Finland: Master file-Reporting structure: According to new guidance No.A129/200/2017 published on 29 January 2018, master file must contain organizational structure data based on § 14b (1) (1) VML. It must contain information about the legal ownership structure of the group of companies.
Local file-Information: According to new guidance No.A129/200/2017 published on 29 January 2018, the local file must contain a description of the organizational and management structure, including the internal reporting requirements for the management.
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Ukraine: Requirements-Control: On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes.
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Requirements-Control: On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate rights of a legal entity of a non-resident in the amount of 24 percent. According to tax code, an individual qualifies as a related person if the individual directly and / or indirectly owns 20% or more corporate rights of the shares of a non-resident legal entity. Therefore, holding 24% will be regarded as related.
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Hong Kong: Information exchange-Multilateral: On 2 February 2018, the Inland Revenue Department published a law in the official gazette outlining the legal framework for Hong Kong to join a multilateral tax agreement on implementing automatic exchange of information in tax matters (AEOI), automatic exchange of CbC reports of multinational entities, and spontaneous exchange of information on tax rulings.
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Norway: Adjustments-MAP: On 7 February 2018, the Ministry of Finance published mutual agreement procedure (MAP) guidelines that apply under Norway’s network of income tax treaties. The Norwegian MAP guidelines provide guidance regarding the use of MAP rules in specific taxpayer cases. The guidance is general in nature, but on certain points, it provides specific guidance relevant for cases related to transfer pricing.
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US: APAs-Fees: On 6 February 2018, the Internal Revenue Service (IRS) announced that fees for Advance Pricing Agreements (APAs) are expected to increase in a two-step process. For APA requests submitted after June 30, 2018, the fees will increase as follows: $86,750 for new APAs; $48,500 for renewal APAs; $42,000 for small case APAs; and $17,750 for amendments to APAs. For APA requests submitted after December 31, 2018, the fees will increase to the following amounts: $113,500 for new APAs; $62,000 for renewal APAs; $54,000 for small case APAs; and $23,000 for amendments.
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Pakistan: CbC reporting requirement-General rule: On 31 January 2018, the Federal Board of Revenue has published SRO no. 99(I)/2018, which provides amendments to draft rules that establish transfer pricing documentation and country-by-country (CbC) reporting requirements for large multinational companies.
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CbC reporting requirement-General rule: On 9 February 2018, FBR published S.R.O. 144(I)/2018 including a clarification that a “constituent entity” for purposes of the country-by-country reporting rules includes a permanent establishment in Pakistan of a non-resident person.
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Poland: Documentation-Thresholds: On 31 January 2018, Ministry of Finance has published general interpretation No.DCT.8201.1.2018 on the thresholds for the obligation to prepare transfer pricing documentation. The guidance clarifies that in determining whether transfer pricing documentation must be prepared in respect of a transaction of a single type.
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Turkey: APAs-Availability of APA: The General Communiqué No. 3 regarding application process of Advance Pricing Agreements (APAs) was published on December 7, 2017 in the official gazette. It was entered into force on the similar day of its publication in the official gazette. The Revenue Administration published draft General Communiqué No. 3 on October 24, 2017.
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Mexico: Specific TP compliance: On 15 February 2018, Mexico has modified its tax legislation, which include changes to the due date for the Tax Situation Information Return (Declaración Informativa sobre Situación Fiscal or DISIF) and deadlines to file some of the transfer pricing returns for fiscal year (FY) 2017, which is no later than 31 March.
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New Zealand: Restriction on interest deduction: On 14 February 2018, government announced that it will recommend a change to transfer pricing provisions in a bill designed to curtail tax avoidance by multinationals specifically restriction on interest deduction on related party cross-border debt.
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Czech Republic: Information exchange-Multilateral: On 14 February 2018, the Cabinet of the Czech Republic approved the OECD Multilateral Convention (MLI). The Czech Republic submitted ITS MLI position at the time of signature, listing its reservations and notifications and including 87 tax treaties it wishes to be covered by the MLI.
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Singapore: Main corporate income tax rate: To ease business costs and support restructuring by companies, on 19 February 2018 the Minister for Finance announced in the Budget 2018 speech that the CIT Rebate for YA 2018 will be raised to 40% of the corporate tax payable subject to a cap of $15,000. In addition, the CIT Rebate will be extended to YA 2019 at 20% of the corporate tax payable, subject to a cap of $10,000.
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Financial services-General: On 23 February 2018, the tax authority published the fifth edition of its transfer pricing guidelines. The guidelines provide guidance on the application of the arm’s length principle for granting a loan by a related party to repay an existing loan (ie refinancing) or to extend the tenure of an existing loan with related parties.
Documentation-Requirement: On 23 February 2018, IRAS published the fifth edition of its transfer pricing guidelines. The guidelines provide guidance on transfer pricing documentation pursuant to Section 34F of the ITA and the transfer pricing documentation rules, which take effect from the year of assessment 2019.
Documentation-Thresholds: Pursuant to the 5th edition of the TP Guidelines, taxpayers are required to prepare TP documentation if they meet either the gross marginal yield condition (trade or operations exceed SGD 10 million) or are prepared for the previous base period.
Documentation-Penalty for documentation failure: Under the new Section 34F (8), which was included in the revised TP Guidelines of the 5th edition, the taxpayer will be fined up to SGD 10,000 per violation if the required transfer pricing documents have not been made.
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Russia: Financial services-Restriction on interest deduction: On 9 February 2018, the Ministry of Finance (MoF) has issued “Guidance Letter No. 03-03-06/1/87340 of 27 December 2017” on the interaction between the country’s thin capitalization rules and a tax treaty.
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Lithuania: Master file-Information: Pursuant to the draft order released on 15 January 2018, taxpayer would be required to renew its Master file under the transfer pricing documentation rules every three years if all conditions of the controlled transaction remained unchanged.
Local file-Information: Previously, companies had to prepare a Local file if the company’s income exceeded approximately €2.9 million. Pursuant to the draft order released on 15 January 2018 the threshold would be increased to €3 million under the draft order.
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