Our transfer pricing services support transfer pricing policies with strategic documentation and help resolve disputes.
The main services we offer are as follows;
- Reviewing all transactions with related parties and reviewing the company's transfer pricing policies,
- Analysing the profit obtained and the prices used in the transactions in question (determining the profit margin, licence rate, interest rate, price, etc. of the transfer price as a result of economic analysis and database research)
- Determining the most appropriate transfer pricing method for the nature of related transactions within the scope of the functions and risks performed by the company,
- Examination of contracts and transaction terms and conditions related to related person transactions,
- Following tax inspections, analysing the inspection report in terms of legislation and practice, advising on the strategy to be determined by the company at this stage and providing support in the subsequent reconciliation and litigation processes.
Documentation services are mainly;
- Annual transfer pricing form
- Annual transfer pricing report and Masterfile
- Preparation of Country by Country Reporting (CbCR).
- As a result of the amendment made to Article 13 of the Corporate Tax Law No. 5520 with the Law No. 6728, it has been ruled that the tax penalty will be applied with a 50% discount for taxpayers who fulfil their transfer pricing documentation obligations in full and on time, even if a criticism of disguised profit distribution is made as a result of a possible tax inspection.
- In addition, transfer pricing documentation is a defence tool that allows taxpayers to be prepared in advance for retrospective studies on related transactions, which may be burdensome in terms of both time and cost, and to demonstrate that a consistent transfer pricing policy is applied.