Legal regulation regarding transfer pricing in Turkey; General Communiqués on Disguised Profit Distribution through Transfer Pricing No. 1 and 2, made in Article 13 of KVK No. 5520 and published in the Official Gazette dated 18 November 2007 and 22 April 2008, and BKK No. 2007/12888 dated 6 December 2007. Regulations regarding implementation have also been made.

In addition, with the amendment made to the Income Tax Law No. 193, parallel regulations were introduced regarding transfer pricing to the regulations in the Corporate Tax Law.

Transfer pricing regulations were introduced to prevent companies from engaging in unfair tax competition internationally and to prevent the tax base from being eroded in the purchase and sale of goods and services carried out by group companies. In parallel with the development of international trade, transfer pricing has become one of the priority issues of fiscal administrations and taxpayers.

• Fulfilling annual report and documentation obligations regarding transfer pricing,
• Analyzing the transfer pricing policies currently implemented by the company and planning the transfer pricing studies,
• Conducting peer analysis using transfer pricing global peer analysis databases,
• Consultancy services in current or potential lawsuits and tax audits regarding Transfer Pricing,
• In case of any dispute with the Tax Administration regarding transfer pricing, taking action to resolve the dispute,
• Managing the agreement process of taxpayers who request to make an Advance Pricing Agreement with the Ministry of Finance,
• Preparation of annual transfer pricing report,
• Support services for filling out the “Form Regarding Transfer Pricing, Controlled Foreign Institution and Thin Capital” included in the annex of the Corporate Tax Declaration.