Legal regulations in Turkey on transfer pricing was made in Article 13 of the Corporate Tax Law no. 5520, and regulations on the implementation were made with the General Communiqués on Distribution of Hidden Incomes by Transfer Pricing serial no. 1 and 2, which were published in the Official Gazettes dated November 18, 2007 and April 22, 2008, and Cabinet Decision no. 2007/12888 dated December 6, 2007.
In addition, with the amendment made to the Income Tax Law no. 193, regulations in line with those regulations contained in the Corporate Tax Law, in relation to transfer pricing, were introduced.
Transfer pricing regulations were introduced for the purpose of preventing companies from making unfair tax competition in the international arena and precluding erosion of the tax base in the purchase and sale of goods and services by group companies. In parallel with the development of international trade, transfer pricing became one of the prioritized issues of Financial Administrations and taxpayers.
Our Transfer Pricing Services consist of the following;
• Fulfill the annual report and documentation obligations in relation to transfer pricing,
• Analyze the transfer pricing policies currently carried out by the company and plan transfer pricing practices,
• Carry out peer analysis by using transfer pricing global peer analysis databases,
• Consultancy services in existing or possible lawsuits and tax inspections in relation to transfer pricing,
• When a dispute arises with the tax administration in relation to transfer pricing, take action to resolve the dispute,
• Manage the agreement process of those taxpayers requesting a Cash Pricing Agreement with the Ministry of Finance,
• Prepare the annual transfer pricing report,
• Support Services for filling the “Form for Transfer Pricing, Controlled Foreign Institutions and Hidden Capital”, which is enclosed with the Corporate Tax Return.