Transfer Pricing 2017

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Turkey's transfer pricing rules came into effect on 1 January 2007. The transfer pricing provisions of article 13 of the Turkish Corporate Income Tax Code (CIT) incorporate the arm's-length principle. In a transaction for the sale and purchase of goods and services between related parties, a price is considered to be at arm's length if the price is such that the parties to the transaction could have reasonably agreed to the price, had they been unrelated.

The regulations concerning transfer pricing are as follows:

  • Decree No. 2008/13490 Concerning the Amendment of the Resolution Concerning Disguised Profit Distribution through Transfer Pricing of 13 April 2008;

  • Decree No. 2007/12888 Concerning Disguised Profit Distribution through Transfer Pricing of 6 December 2007;

  • General Communiqu é No. 1 Concerning Disguised Profit Distribution through Transfer Pricing of 18 November 2007; and

  • General Communiqu é No. 2 Concerning Disguised Profit Distribution through Transfer Pricing of 22 April 2008.

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