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Transfer Pricing Laws and Regulations in Turkey

The Turkish Revenue Administration is responsible for enforcing tax laws, including those related to transfer pricing.

Transfer Pricing Documentation

• All corporate taxpayers are required to prepare transfer pricing documentation.
• Personal income tax taxpayers (individuals) do not have to prepare transfer pricing documentation but can be asked to provide information on related-party transactions if requested by the tax administration or inspectors.

Advance Pricing Agreements (APA)

Turkey has a formal APA program that allows for unilateral, bilateral, and multilateral APAs. There are no specific timelines for filing an APA request, but APAs can be entered into for a maximum period of five years.

Safe Harbours

• Turkey does not have rules on safe harbors for certain industries, types of taxpayers, or types of transactions.

Year-End Adjustments and Secondary Adjustments

Taxpayers are allowed to make year-end adjustments. In cases of non-arm’s length related-party transactions, profits arising from these transactions are considered constructive dividends (disguised profit distributions).

Attribution of Profits to Permanent Establishments

Turkey does not explicitly mention following the Authorized OECD Approaches for the attribution of profits to Permanent Establishments.

Mutual Agreement Procedures and Convention on Mutual Administrative Assistance in Tax Matters

• Turkey has a formal MAP profile, indicating it is able to enter into unilateral, bilateral, and multilateral APAs.
• It is also one of the signatories of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA).

Other Relevant Information

• Turkey is a member of the Convention on Mutual Administrative Assistance in Tax Matters and one of the signatories of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA).