Transfer Pricing Service

Transfer pricing regulations aim to prevent erosion of the tax base and unfair international tax competition in transactions of goods and services between related parties, in line with the Corporate Tax Law, OECD Transfer Pricing Guidelines, and BEPS (Base Erosion and Profit Shifting) Action Plans. Accordingly, prices applied between group companies must comply with the arm’s length principle, reflecting market prices under similar conditions between unrelated parties.

Under current transfer pricing legislation and OECD standards, it is mandatory to prepare annual transfer pricing reports, ensure that reporting aligns with the company’s global organizational structure and value chain, and accurately complete the relevant forms attached to the corporate tax return. In this context, related-party transactions are evaluated through functional analysis, risk assessment, and comparability studies, while end-to-end advisory services are provided for reporting and filing processes.

Scope of Services:

• Analysis of existing transfer pricing policies, agreements, and pricing structures of multinational group companies, with strategic recommendations to senior management, in accordance with OECD guidelines and Turkish legislation
• Design of BEPS-compliant transfer pricing structures for mergers, acquisitions, restructurings, and new company formations
• Technical support for completing the corporate tax return annex, including the “Transfer Pricing, Controlled Foreign Corporation, and Thin Capitalization Form”
• Advisory and defense services for transfer pricing audits conducted by the Ministry of Treasury and Finance, including cross-border risk management
• Preparation of the mandatory Annual Transfer Pricing Report, and support for all documentation requirements