SERVICES - Transfer Pricing

Reporting / Documentation

Taxpayers are obliged to prepare, keep and to present documents to prove their transactions with related parties satisfying the arm’s length principle and the details of their transfer price calculations.
All corporate income tax payers in Turkey have to fill a detailed “transfer pricing declaration” form and attach the form to the corporate income tax return, if only there is any transaction related with transfer pricing and/or thin capital and/or participated foreign company abroad.

Taxpayers must also issue an annual report to certify transactions with related parties and calculations of transfer prices are comply with the transfer pricing rules.

These documents and reports are asked by the tax administration or tax scrutiny authorities.
Transfer Pricing Report is delivered upon conducting our detailed researches, analysis, calculations and services of assessment, planning and management of transfer pricing risks, to design, implement and document of transfer pricing systems to disclosure on timely.

Individual or corporate income taxpayers have to prepare a transfer pricing report in the form of;

I. General
• Info on organisational chart, registrations, business descriptions
• Activity fields
• Functions realised
• Risks
• Assets
• Economic status and conditions
• Market conditions
• Business strategies

II. Related Parties
• Info on organisational chart, registrations, business descriptions
• Activity fields
• Economic status
• Market status and conditions
• Rules and regulations
• Business strategies
• Risks
• Assets

III. Transactions Among Related Parties
Volume of all transactions among related parties and unrelated parties, price lists, production costs, all business contracts, financial statements, accounting standards and methods, intangibles, justification of transfer pricing method and application etc.

IV. Transfer Pricing Analysis
Details of functional and benchmarking analysis.
Internal/external comparables and comparability
Benchmarking criteria
Details of adjustments
Comparison and elimination of transfer pricing methods
Details of the best transfer pricing method used and transfer price applied, such as calculations and statistical method to determine transfer price and/or profit margin and certification, arm’s length price range calculations.

V. Outcome
A summary of the report

More information about Transfer Pricing can be found on the Transfer Pricing information site which can be found at;

Transfer Pricing Tax Advisory Customs
TP Planning / Feasibility

Functional Analysis

Benchmarking / Economic Analysis

Advanced Price Agreements (APA)

Reporting / Documentation

Double Taxation

Customs and Tax Valuation

TP Dispute Solutions

Tax Feasibility

Tax & Accounting Advisory

Tax Certification

Audit & Reporting

Tax Planning

VAT Refunds

Financial Dispute Solutions
Customs Regimes

Customs Valuations

Customs Compliance

Dispute Solutions

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