April 2020: Turkey Draft Communique issued for public comment.
The Draft Communique provides detailed information related to Transfer Pricing Documentation Requirements. The outline is based on the three tier system recommended under OECD’s BEPS Project Action Item 13, covering requirements for a Master File, Local File and Country-by-Country Reporting.
The Local File is similar to the existing requirements for transfer pricing documentation in Turkey and is to be completed for all cross-border transactions, as well as domestic related party transactions in certain circumstances.
The Master File is required for companies where net sales and net assets exceed 500 mil TRY and must be submitted only upon request. Contents of the Master File are similar to the outline provided under the OECD Transfer Pricing Guidelines.