In September 2020, the Turkish Government published The General Communiqué on Disguised Profit Distribution through Transfer Pricing (Series No:4) (the Communiqué) in the Official Gazette. The Communiqué provides detailed information regarding the transfer pricing documentation requirements (e.g., Country-by-Country Reporting) in accordance with Action 13 of the Base Erosion and Profit Shifting (BEPS) project, see EY Global Tax Alert, Turkey issues guidance on transfer pricing documentation requirements, dated 15 September 2020.
Turkish subsidiaries of a Multinational Entity (MNE) group eligible for reporting must notify the Turkish Revenue Administration (TRA) electronically regarding the reporting entity of the MNE group and the jurisdiction where the Country-by-Country (CbC) report has been filed even if the CbC report is not required to be filed in cases where the MNE group's parent entity is located in a jurisdiction with which Türkiye has an information sharing agreement for CbC reporting (CbCR) in place or with which the CbC Multilateral Competent Authority Agreement is activated.
The deadline for submitting a “CbCR Notification” for FY21 period is 30 June 2022.
The TRA has a platform for the submission of the CbCR Notification in electronic form. Taxpayers also may submit the notification form personally or through a local certified public accountant or a sworn-in financial advisor under a tax certification agreement.
For additional information with respect to this Alert, please contact the following:
Kuzey Yeminli Mali Müsavirlik A.S., Istanbul
Ernst & Young LLP (United States), Turkish Tax Desk, New York