Transfer Pricing

Transfer pricing and the distribution of hidden profits under Article 13 of the Corporate Tax Law No. 5520 have become a critical risk area for companies, especially with the increase in related-party transactions and the development of tax administrations' data-driven audit capabilities. These regulations, in effect since January 1, 2007, mandate that companies conduct transactions with related parties in accordance with the arm's length principle.

At Moore Turkey, we approach transfer pricing processes not merely as a compliance obligation, but as a strategic area for managing tax risks and establishing a sustainable tax structure. Through the services we offer within this scope, we support companies in achieving full compliance with regulations and gaining a strong position in potential tax audits.

Within our services, we primarily conduct a detailed analysis of companies' related-party structures, identify risky areas within the definition of related persons, and evaluate existing transaction structures. In line with these analyses, we ensure the restructuring of transfer pricing policies and the creation of an arm's length model, taking into account the company's operating model and industry dynamics.

Within the framework of relevant legislation, related-party transactions conducted domestically and internationally by companies throughout the year are examined in detail; pricing methods are tested for appropriateness, and recommendations for improvement are provided where necessary. In this process, transfer pricing analyses are performed using both internal and external comparables, and potential risks are identified in advance.

In addition, within the scope of transfer pricing documentation obligations;

• Preparation and review of the Annual Transfer Pricing Report
• Under Communiqué No. 4 on Transfer Pricing with Respect to Deemed Profit Distribution
  • Master File Preparation
  • Country-by-Country Reporting Notification Form (CbCR Notification) preparation and submission
  • Country-by-Country Report Preparation
• Services are provided for ensuring the compliance of relevant documentation with legislation.

Moore Turkey not only fulfills reporting obligations in transfer pricing processes but also contributes to establishing a forward-looking, sustainable, and defensible structure. This allows companies to be prepared for potential tax audits and creates a secure tax position by minimizing penalty risks.