Doing Business · Tax

Transfer pricing in Türkiye

2 min read By Level International
In brief Transactions between a Turkish company and its related parties must be priced at arm's length, following OECD methods. Companies document this in an annual transfer pricing form and report; larger groups also prepare a master file and a country-by-country report. Non-arm's-length profit is treated as a disguised profit distribution.
  • Shareholders and companies they control, directly or indirectly

  • Other group companies

  • Directors, managers and their close relatives

  • Counterparties in jurisdictions designated as harmful tax regimes

Methods

Turkish rules follow the OECD Transfer Pricing Guidelines. The taxpayer chooses the most appropriate method:

Method Typical use
Comparable uncontrolled price (CUP) Commodities, loans, some royalties
Cost plus Manufacturing and services for group companies
Resale price Distributors buying from the group
Transactional net margin method (TNMM) Most distributors and service providers in practice
Profit split Highly integrated operations or unique intangibles

Documentation and deadlines

Document Deadline
Transfer pricing form (appendix to CIT return) With the annual corporate tax return
Annual transfer pricing report Ready by the CIT return date; submitted within 15 days if requested
Master file (groups above thresholds) End of the 12th month after year-end
Country-by-country report (groups with EUR 750m+ revenue) End of the 12th month after year-end; notification by the 6th month
  • Thin capitalisation: related-party debt above 3 times equity (6 times for related banks) is thin capital; interest on the excess is non-deductible and treated as a dividend.

  • Financing expense restriction: where total borrowing exceeds equity, 10% of the related financing expense is non-deductible.

  • Controlled foreign companies: passive income of controlled low-taxed foreign subsidiaries can be taxed in Türkiye.

  • Advance pricing agreements: unilateral, bilateral or multilateral APAs can be requested.

Consequences of an adjustment

The excess is added back to taxable income, taxed at 25%, and may also be treated as a dividend subject to withholding, plus penalties and late interest. Good documentation reduces penalty exposure.

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This page provides general information and is not legal or tax advice. Every situation is different; talk to us before you act.

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