Advance pricing agreements
The Advance Pricing Agreement (APA), one of the new institutions introduced with Corporate Tax Law No. 5520, is an alternative solution for taxpayers who do not want to face a potential tax dispute regarding transfer pricing.
According to the Transfer Pricing Statement, APAs take effect from the date of their signing. Furthermore, the evaluation process for an APA application takes at least one to two years, depending on whether the agreement is unilateral or bilateral/multilateral and the structure of the transaction. Taking all these factors into account, it is important to conduct thorough preparation before applying for an agreement, utilize your time effectively, and develop the right strategy.
In this context, TPD’s transfer pricing team will assist you in completing the application process successfully, efficiently, and quickly, leveraging the knowledge and experience it has gained from its previous consulting services on the aforementioned agreements.
Tax audit and consulting:
Tax consulting service.
International tax consulting provides a variety of services including legislation, tax audits, transfer pricing, incentives, digital transformation, and tax practices in special jurisdictions.
Full authentication service.
We deliver the certificate and audit report to the tax office after reviewing the income tax returns, and provide certification services and management reports to managers during the audit.
Services related to technology development zones, R&D and design centers.
We provide advice on tax incentives and social support, help companies maximize legal benefits, and have their accounts audited by a certified public accountant.
Transfer pricing services.
Provides transfer pricing advisory services, including preparing annual reports in compliance with laws, with a focus on compliance with local and international regulations to avoid tax losses.
Merger, division, transfer and liquidation procedures.
We provide consulting on mergers and acquisitions, focusing on financial and legal issues, to maximize profits in accordance with Turkish legislation.
Tax audit and review service.
Tax audit and review services include developing accounting systems, providing tax consulting, examining and analyzing, and preparing financial reports to ensure legal compliance.
Special purpose reporting services.
Required reports include identification of capital payments, equity, partner receivables, profit exclusions, expense confirmation, and identification of corporate statuses and relationships.
Attestation services other than tax matters that we provide within the framework of legal legislation.
The text covers banking and unemployment insurance laws, industrial zone regulation, Ministry of Commerce applications and import control, and financial reporting requirements.
VAT refund service.
Deliveries of goods and services in Türkiye are subject to value-added tax (VAT), with certain exceptions. Some amounts may be refunded under certain conditions.
Advance pricing agreements.
Implementing an advance pricing agreement provides a solution for taxpayers to avoid tax disputes, and requires careful preparation and an evaluation process that extends over a year or two.
Transfer pricing and restructuring advisory services.
Transfer pricing consulting services provide corporate restructuring, transaction reviews, contract evaluations, and benchmarking to improve cost and compliance.
Advisory services on transfer pricing disputes.
TPD provides advisory services to support companies in transfer pricing disputes, including tax audits, legal reviews, and providing recommendations during the dispute stages.
Conversion rate reports and comparative price analysis services.
Turkey's transfer pricing law sets out documentation obligations including annual and international reporting and filing forms to ensure transparency in relevant transactions.
