New Transfer Pricing Regulations

Submission Deadline of First Notification of Country-by-Country Reporting Extended

Recent Development

The Presidential Decree No. 2151, published in the Official Gazette dated February 25, 2020 and No. 31050, and which entered into force on the same date ("Presidential Decree") amended the Council of Ministers' Decree No. 2007/12888 on Disguised Profit Distribution through Transfer Pricing, whereby new transfer pricing documentation rules were introduced.

It was stipulated in the aforementioned Presidential Decree that the members of multinational group of enterprises in scope would be obligated to notify the Tax Administration as to whether they were in the position of an ultimate parent company entity or a surrogate entity; which entity would be reporting on behalf of the group; and any relevant information about the accounting period, by the end of the sixth month following the publication of the Presidential Decree (end of August 2020) for the first