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Turkey Transfer Pricing Rules Amendments — Orbitax Tax News & Alerts

Turkey has made several amendments to its transfer pricing rules through Law No. 6728, published in the Official Gazette on 9 August 2016. The main changes include:

  • The transactional net margin and profit-split methods are added as prescribed acceptable transfer pricing methods (in addition to the comparable uncontrolled price, the resale price, and the cost-plus methods);
  • Taxpayers are allowed to use alternate methods when the arm's-length value cannot be determined by using the prescribed methods;
  • The rollback of advance pricing agreements is allowed, subject to agreement with the tax authorities; and
  • The scope of related parties is changed to include at least 10% direct or indirect partnership interest, voting rights, or dividend rights.

The changes are effective from the date the law was published, 9 August 2016.