On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of transfer prices that the adjustments made in accordance with the LISR(Income Tax Law) will only be applicable when the amounts of the agreed considerations are outside the adjusted interquartile range determined in the analysis.
Therefore, it is considered an improper tax practice to make any modification or adaptation to the prices, amounts of consideration or profit margins of transactions with related parties, when these are already within the determined adjusted range in order to obtain an “undue” tax benefit.
