CIRCULAR Issue: 2020/222

Subject: COMMUNIQUÉ SERIAL NO. 4 AMENDING THE GENERAL COMMUNIQUÉ ON DISGUISED PROFIT DISTRIBUTION VIA TRANSFER PRICING SERIAL NO. 1 WAS PUBLISHED

As it is known through the Presidential Decision dated 25.02.2020 and numbered 2151 published in the Official Gazette with number 31050, transfer pricing reporting standards in line with the Action Plan 13 of the Base Erosion and Profit Shifting (BEPS) of the Organization for Economic Cooperation and Development (OECD) were introduced. This time, Communiqué Serial No. 4 Amending the General Communiqué on Disguised Profit Distribution Via Transfer Pricing, with respect to the said decision, has been published and presented to the opinions and suggestions of the taxpayers.

The communiqué provides details on the three-tiered reporting standards (Country-by-Country Reporting, Master File and Annual Transfer Pricing Report) prepared in the Base Erosion and Profit Shifting (BEPS) Action Plan No: 13 of the Organization for Economic Cooperation and Development (OECD) and included in the OECD's Transfer Pricing Guidelines. With the help of some examples, the Communiqué also clarifies the "10% share of partnership" concept which can be interpreted differently in the definition of related party.

Important topics and explanations regarding the communiqué are provided in the documents below.

Sincerely,

DENGE İSTANBUL YEMİNLİ MALİ MÜŞAVİRLİK A.Ş.

ANNEX:

Communiqué Serial No: 1 Amending the General Communiqué on Disguised Profit Distribution Through Transfer Pricing

(*) The remarks in our circular are for informational purposes only. We recommend that the opinion and support of a qualified counsellor be received before establishing final transactions on the questionable matters. Our company shall not be held responsible for any damages to be incurred as a result of transactions to be made solely on the basis of the statements in our circular.

(**) For opinions, criticisms and questions about our circular, you can contact our specialists the contact information of whom is provided below.

 

Gökçe GÜCÜYENER

Transfer Pricing, Partner

Mazars/Denge TransferPricing

ggucuyener@mazarsdenge.com.tr