miércoles, 9 de noviembre de 2016

Turkey: New law introduces transfer pricing amendments to the Corporate Income Tax Law

The new law (Law No. 6728) introduces amendments in Article 13 of the Corporate Income Tax Law (the CITL) No. 5520. The new regulations aim to eliminate or reduce uncertainties or difficulties faced in the past and also to promote timely and proper compliance with documentation requirements. The amendments set forth in Law No: 6728 can be summarized as follows:

  • Definition of related party is narrowed down to exclude direct or indirect shareholding or voting rights which are less than 10%.
  • Transactional profit methods are added to the Transfer Pricing Regulations.
  • An opportunity for implementing Advance Pricing Agreements (APAs) to previous periods is enabled (roll back).
  • Reduction of tax penalties for taxpayers who fulfill documentation requirements fully and timely is considered (penalty protection).
  • The Law clarifies deducting VAT on disguised profit distribution through transfer pricing.

Source & more info: PwC

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