Post by account_disabled on Mar 16, 2024 5:24:35 GMT -5
The country or there is a systemic error a countrybased report must be submitted to the Administration by the enterprise of the multinational enterprise group resident in Turkey. If the reporting enterprise is a proxy enterprise there is no competent authority agreement in force with the relevant country or there is a systemic error a countrybased report must be submitted to the Administration by the enterprise of the multinational enterprise group resident in Turkey. The first countrybased report will be submitted to the Administration by December for the accounting period.
Enterprises with a special accounting period will submit the relevant report to the Administration by the end of the twelfth month after the end of the special accounting period . Evaluation With the said Presidential Decree new certification obligations regarding transfer pricing were imposed on multinational enterprises and at the same time it was stipulated that if the said B TO B Database certifications are completed fully and on time the tax loss penalty will be applied with a discount for taxes that have not been accrued on time or have been accrued incompletely within the scope of disguised income. In this context timely fulfillment of transfer pricing documentation obligations by multinational enterprises will both provide a protection shield for these enterprises in case of possible investigations and will enable them to benefit from reduced penalty rates in case the transactions are deemed not to be in line with arms length.
Based on this we recommend that multinational enterprises determine whether they have general report masterfile and countrybased report CbCR obligations for the accounting period according to the relevant limits. If the Turkish subsidiaries of foreignbased multinational enterprises are obliged to prepare general reports andor countrybased reports we recommend that they obtain the relevant general reports from the group headquarters and that Turkeybased multinational enterprises subject to reporting prepare their general reports andor countrybased reports without delay.
Enterprises with a special accounting period will submit the relevant report to the Administration by the end of the twelfth month after the end of the special accounting period . Evaluation With the said Presidential Decree new certification obligations regarding transfer pricing were imposed on multinational enterprises and at the same time it was stipulated that if the said B TO B Database certifications are completed fully and on time the tax loss penalty will be applied with a discount for taxes that have not been accrued on time or have been accrued incompletely within the scope of disguised income. In this context timely fulfillment of transfer pricing documentation obligations by multinational enterprises will both provide a protection shield for these enterprises in case of possible investigations and will enable them to benefit from reduced penalty rates in case the transactions are deemed not to be in line with arms length.
Based on this we recommend that multinational enterprises determine whether they have general report masterfile and countrybased report CbCR obligations for the accounting period according to the relevant limits. If the Turkish subsidiaries of foreignbased multinational enterprises are obliged to prepare general reports andor countrybased reports we recommend that they obtain the relevant general reports from the group headquarters and that Turkeybased multinational enterprises subject to reporting prepare their general reports andor countrybased reports without delay.