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Tax Bulletin:


22 February 2021


As mentioned in our Bulletin no.2020/002, with the “Decree Regarding the Chamges in the Decree about Disguised Profit Distribution through Transfer Pricing” No.2151 published in the Official Gazette dated 25.2.2020 and numbered 31050, the 3-tier reporting obligation regarding the Transfer Pricing has been introduced to the Turkish Tax Legislation.

One of the obligations introduced with the Decree is the Country-by-Country Reporting (CbCR). Accordingly, the relevant report will be submitted to the Administration by the ultimate Turkish-resident parent entity of the multinational entity (MNE) group, which is within the scope of the CbCR obligation (consolidated group revenue is EUR 750 million or more). In the event that the ultimate parent entity is not in Turkey and there is no competent authority agreement in force regarding the sharing of CbCR information between the Administration and the country administration of the ultimate parent entity, CbCR must be submitted to the Administration by the Turkish-resident entity of the MNE group (in case of having more than one entity in Turkey, by one entity on behalf of the others).