Transfer Pricing Services
Article 13 of the Corporate Tax Code no. 5520 covers regulations relating to disguised profit distribution through transfer pricing applications. Under these regulations it is stipulated that profits shall be considered to have been wholly or partially distributed in a disguised manner through Transfer pricing, if the entity engages in the deliveries of goods and services with related parties at prices or at amounts which they determine contrary to the arm’s length principle.
Disguised profit distribution through transfer pricing, which is regulated under the Corporate Tax Code no. 5520, requires that the price applied in transactions with related parties is determined in accordance with the arm’s length principle.
Our below mentioned services support taxpayers in terms of creating and maintaining sound transfer pricing policies and resolving TP related conflicts with the tax Authority.
Transfer Pricing Advisory and Controversy Services
- Reviewing all related party transactions and the transfer pricing policy applied.
- Analysis of the pricing and the profit margins applied in the related party transactions and determination of arm’s length price and profit of the transactions via Pan European databases.
- Determination of the most suitable transfer pricing methodology taking into account the functions and the risks of the entity.
- Review of tax assessment reports and determination of the company’s strategy in terms of dispute resolution i.e. appeal and litigation support.
Transfer Pricing Documentation Services
Turkish transfer pricing documentation comprises
- Transfer Pricing Form
- Transfer Pricing Documentation Report
- Masterfile
- Country by Country Reporting
Under the Tax Procedural Code, late filing, incomplete or inaccurate filing of reports are subject to a procedural tax penalty. Additionally, a “Penalty Protection Regime” applies where taxpayers may get a penalty reduction of 50% in the case of full and timely preparation of transfer pricing documentation.
