The main concern of transfer pricing regulations is to prohibit unfair tax competition in the international level and to prohibit tax erosion caused by affiliates’ transactions. Transfer pricing has recently become one of the primary concerns of both taxpayers and tax administrations.

As it is known, according to the arm’s length principle in transfer pricing, companies must apply parallel prices for similar transactions between affiliates and between unrelated companies.

In accordance with current transfer pricing regulations in Turkey, taxpayers within limits are compelled to prepare Master File, Country by Country Report (CbCR) and Annual Transfer Pricing Report, fulfil the CbCR notification and submit the “Form relating to the Transfer Pricing, Controlled Foreign Company and Thin Capital” attached to the corporate income tax return.

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