Türkiye – Transfer Pricing Overview
Türkiye’s transfer pricing regime is designed to ensure that transactions between related parties are conducted in accordance with the arm’s length principle. The legal basis for transfer pricing rules is set out in Article 13 of the Corporate Income Tax Law, which requires that prices, fees, or other consideration applied in related-party transactions reflect conditions that would have been agreed between independent parties under comparable circumstances. Any profits deemed to be shifted through non-arm’s length pricing may be recharacterized as disguised profit distribution and adjusted for tax purposes.
The transfer pricing framework in Türkiye is largely aligned with the OECD Transfer Pricing Guidelines and follows internationally accepted principles, including functional analysis, comparability analysis, and the selection of the most appropriate transfer pricing method. Recognized methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method (C+), Resale Price method (RPM), Transactional Net Margin Method (TNMM), and the Profit Split method (PSM).
The scope of the rules covers a broad range of related-party transactions, including the transfer or licensing of intangible property, intra-group services, financing arrangements, and cost contribution agreements. Taxpayers are expected to demonstrate the economic substance and commercial rationale of such transactions and to maintain adequate supporting documentation. Transfer pricing documentation requirements include the preparation of a Local File, Master File, and Country-by-Country Reporting (CbCR), subject to certain revenue thresholds. Administration and enforcement of these rules are carried out by the Gelir İdaresi Başkanlığı.
Overall, Türkiye’s transfer pricing system reflects a documentation-driven and economically grounded approach, requiring taxpayers to substantiate that their intercompany arrangements are consistent with arm’s length standards and aligned with international best practices.
Türkiye – Transfer Pricing Country Profile
This document below outlines Türkiye’s domestic transfer pricing legislation and administrative practices. it focus on countries' domestic legislation regarding key transfer pricing principles, including the arm's length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures.