Post by account_disabled on Mar 16, 2024 7:29:35 GMT
The the application date The intercompany pricing policy applied to transactions between related parties The information about the volumes of controlled and uncontrolled transactions at the fiscal period which involves transaction date and invoices bank slips and similar documents Related parties financial statements from the previous three years copies of income or corporate tax returns and copies of agreements about foreign transactions The financial data and documents of the previous three years supporting the suggested transfer pricing method If there are two or more comparable transactions the armslength range and the method used in the determination of that range and Other documents required to determine the arms length price.
The tax administration will ask for additional document containing necessary information from the taxpayer if necessary. If documents and information concerned are written in other languages they have to be submitted together with original copies after being translated into Turkish. At the same time the taxpayers who signed an APA with tax administration have to prepare and submit an annual APA report The general terms B TO B Database of annual APA report can be seen at the end of article. covering the transactions within agreement. However documents and papers containing necessary information for the related party transactions that are not covered by the APA must be kept separately in accordance with the documentation rules in transfer pricing legislation. Renewal of an APA According to Turkish transfer pricing legislation taxpayers can request the renewal of an APA. The taxpayer in such a case has to fill in a form to renew an APA no later than nine months before the current APA expires.
The taxpayer should also submit appropriate updated supporting documentation similar to that required for the initial APA request and submission with the renewal request. Revenue administration may renew an APA under similar terms and conditions when both the taxpayer and administration are satisfied that The transfer pricing method in the previous APA continues.
The tax administration will ask for additional document containing necessary information from the taxpayer if necessary. If documents and information concerned are written in other languages they have to be submitted together with original copies after being translated into Turkish. At the same time the taxpayers who signed an APA with tax administration have to prepare and submit an annual APA report The general terms B TO B Database of annual APA report can be seen at the end of article. covering the transactions within agreement. However documents and papers containing necessary information for the related party transactions that are not covered by the APA must be kept separately in accordance with the documentation rules in transfer pricing legislation. Renewal of an APA According to Turkish transfer pricing legislation taxpayers can request the renewal of an APA. The taxpayer in such a case has to fill in a form to renew an APA no later than nine months before the current APA expires.
The taxpayer should also submit appropriate updated supporting documentation similar to that required for the initial APA request and submission with the renewal request. Revenue administration may renew an APA under similar terms and conditions when both the taxpayer and administration are satisfied that The transfer pricing method in the previous APA continues.