The Revenue Administration published draft General Communiqué No. 3 on October 24, 2017 regarding transfer pricing. This provides amendments to Section 6 of General Communiqué No. 1. According to draft General Communiqué No. 3, definitions of advance pricing arrangement (APA), unilateral, bilateral and multilateral APAs will be included to section 6-Advance Pricing Agreements of General Communiqué No. 1.
An assessment and analysis will be finalized within 6 months for unilateral APA applications. An evaluation and analysis phase will be completed within 12 months for bilateral or multilateral APA applications.
As a result of the evaluation and analysis carried out by the Administration, the taxpayer application is accepted as it is and may accept or refuse it, provided that necessary changes are made. The unilateral prepayment agreements of the evaluation and analysis process will be completed within 9 months from the application date. The contract with the Administration the period may be extended, if in case the application cannot be finalized within this period. A bilateral or multilateral APA process will be completed within 18 months from the date of application. In case the application cannot be concluded within this period, the period may be extended if the taxpayer agrees.
Pricing agreement form is also available in Turkish government site.
Comments on the communiqué are requested to submit through Revenue Administration’s website by October 31, 2017.
