Transfer Pricing Documentation Obligations in Turkey Article 13 of Corporate Income Tax Law, regulating transfer pricing rules, was amended through the Law No. 6728 on the Improvement of the Investment Environment and in this scope additional authority was given to the Turkish President to determine transfer pricing procedures. The Presidential Decree No.2151 exercises this authority…
General Advance pricing agreements (APAs) are defined by the OECD transfer pricing guidelines for multinational enterprises and tax administrations as an appropriate set of criteria (for example transfer pricing method, comparables and appropriate adjustments thereto, critical assumptions as to future events) for the determination of the transfer pricing for those transactions over a fixed period…
When establishing a company in Turkey, one needs to adhere to the following rules and regulations: Submitting the memorandum and articles of association online at MERSIS Pursuant to the Trade Registry Regulation, trade registration transactions must be fulfilled through MERSIS (Central Registry Record System). MERSIS is a central information system for carrying out commercial…
Government policy Describe the general government/regulatory policy for transfer pricing in your jurisdiction. To what extent is the arm’s-length principle followed? Article 13 of the Corporate Income Tax Law covers the key provisions regulating transfer pricing rules in Turkey. The Individual Income Tax Law also contains certain transfer pricing provisions. In addition, as Turkey is…
The regulations developed by the OECD regarding the Global and Domestic Minimum Top-up Tax (“Pillar 2”) introduce a 15% global minimum effective tax for in-scope large multinational enterprise (MNE) groups. Türkiye is among the countries that adopted this system at an early stage and has comprehensively integrated it into its domestic legislation. Within…
Important Amendments to the Corporate Income Tax General Communiqué The amendments to the Corporate Income Tax General Communiqué No. 1, through Communiqué No. 23, have been published in the Official Gazette, dated 28/9/2024. This Communiqué outlines the significant regulations introduced by seven different laws enacted over the past three years and updates certain figures and…
The “Local and Global Minimum Top-Up Corporate Income Tax” (MTUT) regulation, which entered into force in Turkey on August 2, 2024, and was added to Corporate Income Tax Law No. 5520, represents a significant turning point in the global taxation architecture. These regulations, in line with the Model Rules and Commentary established by the OECD/G20…