Turkey's revenue administration on 16 March 2016 issued a
draft communiqué that, once finalized, would expand certain
legal requirements and would introduce new transfer pricing
documentation rules that generally follow the base erosion and
profit shifting (BEPS) Action 13 recommendations and provide for
country-by-country reporting.
The draft communiqué introduces new definitions and
determinants for the concept and scope of treasury loss. Public
comments on the new draft communiqué are due within a 15-day
period.
Draft communiqué
The March 2016 draft communiqué—referred to in
English as "General Communiqué on Disguised Profit
Distribution through Transfer Pricing Serial No:
3"—proposes changes and amendments to earlier
guidance—"General Communiqué on Disguised Profit
Distribution through Transfer Pricing Serial No: 1"—that
has regulated Turkey's transfer pricing rules effective since 1
January 2007.
