SUBJECT: Explanations on Transfer Pricing Communiqué No 4


In the General Communiqué on Disguised Profit Distribution by Way of Transfer Pricing (No.1 General Communique on Transfer Pricing) The amending Communiqué on Transfer Pricing No.4 (Communiqué No.4) was published in the Official Gazette numbered 31231 dated September 1, 2020.

In case the companies within the scope of Transfer Pricing meet the necessary conditions with the Communiqué No. 4, they are obliged to prepare the following reports and some forms regarding the transfer pricing certification obligations.

1.1. General Report

The general report is prepared by corporate taxpayers who are affiliated with the multinational business group and whose asset size in the balance sheet and the net sales amount in the income statement are both 500 million TL and above, which are attached to the corporate tax declaration for the previous accounting period.

The general report must be prepared by corporate taxpayers affiliated to the multinational group of businesses until the end of the fiscal period following the relevant fiscal period and, if requested after the end of this period, it must be submitted to the Administration or to those who are authorized to conduct tax inspection. The first General Report will be prepared for the 2019 accounting period until 31/12/2020, those subject to the special accounting period will prepare the first General Report for the accounting period starting after 1/1/2019.

1.2. Annual Transfer Pricing Report

Annual transfer pricing reports, which have already been prepared as of 2007, will continue to be prepared by the corporate taxpayers, which are also within the scope, until the deadline for the submission of the relevant period’s corporate tax return. As it is known, this report is not required to be attached to the corporate tax return and submitted to the tax office unless it is officially requested.

1.3. Country Based Report

The total consolidated Group revenues compared to the consolidated financial statements for the year 2018 750 million Euros and over Multinational Business Group’s Turkey the ultimate parent company proxy or business ubre the reported accounting period until the end of the twelfth month, which for the year 2019 It will prepare until 31.12.2020 and submit it to the Financial Administration electronically.

In case of being subject to the special accounting period, the first country-based report should be prepared for the accounting period starting after 1/1/2019 and submitted to the Administration electronically until the end of the twelfth month following the end of the relevant special accounting period. For example; A taxpayer whose special accounting period ends on 31 March and is included in the scope will prepare the first ÜBR for the special accounting period of 1 April 2019 – 31 March 2020 until 31 March 2021 and submit it to the Financial Administration electronically.


Transfer Pricing Communiqué No.4, related to the circular, is attached.