Preparation Of Transfer Pricing Reports Services

In accordance with the transfer pricing legislation in force in Turkey, taxpayers have certain documentation obligations. These are the preparation of three separate reports in case of certain conditions and the submission of the annual transfer pricing form  and country -by-country form to the tax administration.

TRANSFER PRICING REPORTING OBLIGATIONS:

1. General Report (Master File)
2. Country-by-Country Report and form
3. Annual Transfer Pricing Report
4. Transfer Pricing Form

GENERAL REPORT (MASTER FILE):

It is prepared by corporate taxpayers who are affiliated with multinational enterprises group and whose asset size in the balance sheet and net sales amount in the income statement are both 500 million TL and above.

Accordingly, in order to prepare a general report on an accounting period;

1. a) Being a corporate taxpayer affiliated with a multinational business group,
2. b) The asset size in the balance sheet and the net sales amount in the income statement in the annex of the corporate tax return for the previous accounting period must both be 500 million TL or more.

ANNUAL TRANSFER PRICING REPORT:

It is the preparation of the annual transfer pricing report regarding the transactions carried out with related parties until the date of submission of the corporate tax return and submitting it to the Financial Administration or those authorized to conduct tax inspections, if requested.

COUNTRY- BY -COUNTRY REPORT AND FORM:

Country-by-Country Report and form, unlike the General report, is essentially a reporting obligation consisting of 3 tables.

According to the consolidated financial statements of the accounting period preceding the reporting period, the ultimate parent or proxy business of the multinational group of companies with a total consolidated group income of EUR 750 million and above, prepares the country-based report until the end of the twelfth month after the reporting period. and submits it to the Administration in electronic form.

TRANSFER PRICING FORM:

It is the declaration of related transactions and persons in terms of transaction type, transaction amount and method by filling out the transfer pricing form attached to the corporate tax return.

The two types of certification obligations mentioned above are essentially interrelated and complementary to each other. For this reason, the information about the related persons and transactions specified in the form attached to the declaration and the explanations made in the transfer pricing reports should be consistent with each other.

The timely fulfillment of annual documentation obligations is a process that will help taxpayers to be prepared in advance for studies that will impose a great burden on their related transactions, both in terms of time and cost, and to demonstrate that a consistent transfer pricing policy has been applied in the event that they are subject to a future tax examination.

In addition, during the transfer pricing documentation, a macro-level analysis is made about the functions and risks undertaken by the company in its related transactions, and an important opportunity is provided for the company to take the necessary measures.

IN THIS CONTEXT, THE SERVICES PROVIDED BY OUR COMPANY ARE AS FOLLOWS;

• Establishing your company’s function and risk structure,
• Reviewing your company’s transfer pricing policies,
• Examining agreements regarding related transactions,
• Determining the most appropriate transfer pricing method for the nature of the related transactions,
• Supporting related transactions with economic analyzes and different database researches in terms of internal and external precedents
• Preparation of Transfer Pricing reports