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Inland Revenue Authority of Singapore (“IRAS”) has introduced the indicative margins for related party loans since the past few years whereby the indicative margins are updated at the beginning of each calendar year.

The introduction of Earning Stripping Rules (“ESR”) limiting the interest deduction for financial assistance between related persons were announced in the Budget 2018.

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On 01 November 2018, the Inland Revenue Board of Malaysia (“IRBM”) had a dialogue session with the Chartered Tax Institute of Malaysia (“CTIM”)’s Technical Committee on the updated version (mainly from Chapters II to XI) of the Malaysian Transfer Pricing Guidelines (“TP Guidelines”)

With the recent focus on profit shifting around the world, guidance on profit split method has revised by Organisation for Economic Co-Operation and Development (“OECD”) in June 2018. OECD published the “Revised Guidance on the Application of the Transactional Profit Split Method” under Base Erosion Profit Shifting (“BEPS”) project - Action 10.

On 13 July 2018, Hong Kong’s new transfer pricing regime was enacted through the Inland Revenue (Amendment) (No. 6) Ordinance 2018 (“Amendment Ordinance”). This new law codifies transfer pricing rules in Hong Kong and is largely consistent with the OECD transfer pricing guidelines.