Transfer Pricing Advisory

Global Compliance, Transparency, and Defensibility in Intra-Group Transactions

In today’s global tax environment, goods, services, intangibles and financing transactions (intra-group transactions) carried out by multinational companies between their subsidiaries are among the areas that tax administrations examine and focus on the most . With the OECD’s Base Erosion and Profit Shifting (BEPS) action plans, documentation obligations and demands for transparency in this area have increased on a global scale.

As LEVEL INTERNATIONAL, we are at your side with our command of not only local legislation but also the OECD Transfer Pricing Guide and international best practices. Our aim is to place the pricing policies both in Turkey and between your international group companies on an accurate and always defensible basis that coincides with commercial realities, in line with the “Arm’s Length Principle”.

Our Service Scope

We manage the transfer pricing process with a holistic approach on three main axes, from strategy determination to documentation and management of potential disputes:

Legal Documentation and Reporting

We prove the transparency of your intra-group transactions with reports in accordance with national and international standards.

Creation of Policy Documents: Writing down consistent transfer pricing policies to be implemented across the Group.
Master File: Preparation or revision of the high-level report describing the multinational group’s global operating structure, value chain and general transfer pricing policies.
Annual Transfer Pricing Report (Local File): Preparation of a local report detailing the transactions of your company in Turkey with related parties in accordance with the legislation.
Country-Based Reporting (CbCR) and Notifications: Preparation of the CbCR report showing the Group’s worldwide income, tax and activity distribution and management of management of XML formatting and submission processes.

Strategic Analysis, Methodology and Precedent Studies

We base the economic basis of your pricing policies on solid data.

Method Determination and Functional Analysis: Determining the most appropriate transfer pricing method (comparable price method, Cost Plus Method, Transaction-Based Net Profit Margin Method, etc.) and conducting detailed functional analyses revealing the risks undertaken by the parties and the assets they use.
Benchmarking: Conducting economic analyses and benchmarking studies that prove the arm’s length of intra-group pricing using internationally licensed databases.
Risk Analysis and Structure Optimization: Identifying potential transfer pricing risks in your existing structure in advance (Check-up) and designing efficient structures suitable for the business model.

Conflict Management and Authority Relations (Defense and Preventive Solutions)

We protect you with our technical expertise in processes with tax administrations.

Tax Inspections and Audit Consultancy: Providing technical support from the beginning to the end of the process in a possible transfer pricing review, developing defense arguments and managing communication with the administration.
Advance Pricing Agreements (APA): Conducting APA processes to eliminate ambiguity by agreeing in advance with the Tax Administration on the method to be applied in future transactions.
Mutual Agreement Procedure (MAP): Technical support in MAP processes carried out between the competent authorities of countries for the solution of double taxation problems.

Turkish Tax Consultancy

We empower you to navigate Turkey’s dynamic and complex tax legislation with confidence.