The revenue administration in Turkey in early April 2015 published advance pricing agreement (APA) draft guidelines as information for taxpayers that may be interested in applying for an APA.
In general, the draft guidelines sets forth information that is required or that may be requested by the tax authorities with respect to APA applications.
Advance pricing agreements (APAs) are available in Turkey pursuant to the fifth clause of article 13 of the corporate tax law, number 5520, “Disguised Profit Distribution through Transfer Pricing.”
An APA may be available for taxpayers to resolve potential tax disputes regarding the transfer pricing methodology selected for designating the transfer prices of products or services either purchased from or sold to related parties.
Detailed information on the APA process provided in the draft guidelines:
An advantage of an APA is that a taxpayer that may be hesitant as to which transfer pricing methodology to use will obtain certainty from the tax authorities, with respect to the transfer pricing methodology to be used for a specific period of years. With the recent release of the draft guidelines, taxpayers in Turkey now have information about what information they are to supply to the revenue administration in their application petitions. The new guidance is expected to facilitate the length and efficiency of the APA processes in Turkey.