Transfer pricing regulations were initiated in order to prevent companies taking in part of harmful tax competition in the international arena and to prevent tax erosion arising from related party transactions. Parallel to the development of international trade, transfer pricing has become a matter of priority for tax administrations and taxpayers.

According to arm’s length principle in transfer pricing, the prices applied for transactions between related parties must be parallel to those which are applied between unrelated parties for similar transactions.

Taxpayers within certain limits, obliged to prepare an Annual Transfer Pricing Report, Master File and Country by Country Report (CbCR), fulfill the CbCR notification, and submit the “Form relating to the Transfer Pricing, Controlled Foreign Company and Thin Capital” attached to the corporate income tax return.

As BDO, we provide the transfer pricing services listed below:

• Preparation of annual transfer pricing reports,
• Preparation of Country by Country Report,
• Fulfilling the CbCR Notification,
• Preparation of Master File
• Evaluation of current transactions and agreements within the frame of transfer pricing regulations,
• Establishing optimal structures from transfer pricing perspective,
• Assisting in Advance Pricing Agreement process with Ministry of Finance,
• Providing services to assist with filling of “Form relating to the Transfer Pricing, Controlled Foreign Company and Thin Capitalization” attached to corporate income tax return,
• Consultancy services to tax inspections

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