The author outlines the competent authority process in
Turkey, explaining which taxpayers are eligible and describing
common issues as well as how the process interacts with
litigation.
Turkish transfer pricing regulations effective in
20071 are expected to increase audits and, as a result,
the number of applications for mutual agreement procedure cases.
Until recently, application procedures were not clearly stated by
the Turkish Revenue Administration (TRA). MAP guidelines published
by the TRA's European Union and Foreign Relations Division
(Avrupa Birligi ve Dis Iliskiler Daire Baskanligi) July
31, 2009, however, should give taxpayers a better understanding of
the requirements for obtaining a MAP, the types of issues
appropriate for the procedure, and what remedies a taxpayer may
seek in court without forfeiting its right to the competent
authority process.2
