President Decree ("Decree") on the Amendment of the
Decision on Disguised Profit Distribution Through Transfer Pricing
entered into force after being published in the Official Gazette
dated February 25, 2020 and numbered 31050. Article 19 of the
related Decree has been changed together with its title and also
Article 19/A titled "Documentation and Remission" has
been added to the same Decree. Pursuant to 19th Article of the
Decree titled "Documentation"; The certification consists
of a master file, local file, and a country by country report.
1) Master File
The master file includes the organizational structure of the
multinational group of company, the definition of the company's
operating activities, intangible rights, intra-group financial
transactions and tax status.