On 16 March 2016, Turkey's tax authority issued a draft communiqué for public comment on new transfer pricing documentation requirements based on the guidelines developed as part of Action 13 of the OECD BEPS Project; including requirements for:

• Country-by-Country (CbC) report;
• Master file; and
• Local file

CbC Report

The draft CbC reporting requirement will apply for ultimate parent entiti…