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Transfer Pricing Legislation has been in force in Turkey, in compliance with the OECD Transfer Pricing approach, since January 2007. The Turkish transfer pricing regulations are the «Corporate Tax Law No. 5520, Article 13» and the «General Communique on Disguised Profit Distribution through Transfer Pricing (Serial No: 1, Serial No: 2 and Serial No: 3)». The importance of transfer pricing will continue to increase in line with international developments led by the OECD/G20 Base Erosion and Profit Shifting (“BEPS”) Project.

What is the Arm’s Length Principle?

How can we help you as Mazars Denge?

The Arm’s Length Principle indicates that the price or amount applied in the purchase and sale of goods or services performed with related parties should be in compliance with the price or amount to be incurred in the absence of such a relationship.

Consultancy Services Transfer Pricing Risk Analysis Transfer Pricing Planning Advanced Pricing Agreement (APA) Support Value Chain Analysis in Compliance with BEPS Preparation and Analysis of Intra-Group Contracts

What if the Arm’s Length Principle is violated?

Documentation Master File

If a taxpayer trades with related parties at a price or amount determined to be in contravention of the Arm’s Length Principle, the relevant earnings will be deemed to have been distributed as disguised profit by means of transfer pricing. Disguised profit distribution through transfer pricing will not be deducted from the corporate tax base.

Local File (Annual Transfer Pricing Report) Country by Country Reporting (CbC)

CbC Consultancy Services Benchmark Analysis Financial Services License, Royalty, Know-How Manufacturing, Distributor, Commission

What are the tax penalties and implications?

Primary Adjustment: Corporate Tax Adjustment Secondary Adjustment: Dividend Withholding Tax Adjustment Double Taxation and Tax Disputes

Intra-Group Services Training Transfer Pricing Training for Different Levels Discrepancy Transfer Pricing Dispute Consultancy

CONTACT Hürriyet Mah. Dr. Cemil Bengü Cad. Hak İş Merkezi No:2 K:1-2 Çağlayan 34403 Kağıthane/İstanbul T: (+90 212) 296 51 00 F: (+90 212) 296 51 44

Gökçe GÜCÜYENER Transfer Pricing Partner

Transfer Pricing Services  
Transfer Pricing Services