The Turkish Ministry of Treasury and Finance has issued a formal statement regarding the implementation of Amount B under Pillar One on 7 March 2025, a key component of the OECD/G20 Base Erosion and Profit Shifting (BEPS) framework, developed by the Inclusive Framework (IF). This announcement follows the OECD’s release of the Consolidated Report on Amount B.
According to the Ministry’s announcement, the first phase of the Amount B initiative has been finalized with the publication of a report on 19 February 2024, now integrated into the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Amount B is set to apply to accounting periods starting on or after 1 January 2025, although participation remains optional for countries.
The framework outlines that countries can choose to apply Amount B to transactions involving distributors, sales agents, and brokers within their jurisdiction starting from 1 January 2025. The OECD published the consolidated guidelines on Amount B on 24 February 2025.
However, Türkiye has confirmed that it will not adopt Amount B for transactions involving distributors, sales agents, and brokers operating within its borders at this stage. As a result, Turkey will continue to rely on traditional transfer pricing methods, utilizing benchmarking studies to assess arm’s length pricing, rather than implementing the OECD’s predefined profit margin calculations for covered transactions.
