• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 7/23/2013

Turkey - Review of APA rules, process 

July 23: Turkey’s advance pricing agreement (APA) system is still viewed as being in its infancy, even though Turkey’s transfer pricing rules were effective beginning in 2007.

To date, only three unilateral APAs have been officially signed between taxpayers and the Turkish tax authorities.

However, corporations in Turkey are becoming more aware of the advantages of an APA as a means of resolving transfer pricing disputes.

Read a June 2013 report [PDF 1.5 MB] prepared by the KPMG member firm in Turkey: Advance Pricing Agreement in Turkey

The KPMG report:

  • Describes the transfer pricing and APA systems in Turkey, as well as the global trend toward APAs
  • Provides a diagram mapping the process for reaching an APA in Turkey, and answers the following APA-related questions:
    • Who can apply for an APA?
    • Which types of APAs are accepted in Turkey?
    • Which transactions are within the scope of an APA?
    • What is the application fee for an APA?
    • What is the maximum duration time for APAs?
    • What is the APA processing time?
    • Can Turkey’s tax authorities audit the intercompany transactions covered by APAs?
    • Do APAs cover indirect taxes related to transfer pricing?

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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