Turkey’s Ministry of Treasury and Finance released General Communiqué No. 5 on Transfer Pricing on 17 October 2014.

This Communiqué amends General Communiqué No. 1 on Transfer Pricing and aligns it with new deadlines for Country-by-Country reporting under Presidential Decision No. 8956.

The key amendment concerns revising the reporting deadline outlined in Article 7.4 of General Communiqué No. 1 on Transfer Pricing related to country-by-country (CbC) reporting.

The ultimate parent company or proxy company of a multinational enterprise group resident in Turkey whose total consolidated group revenue is EUR 750 million or more according to the consolidated financial statements of the accounting period preceding the reported accounting period shall prepare a CbCreport by the end of the 12th month following the reported accounting period and submit it to the Administration in electronic format.

If the consolidated financial statements are prepared in a currency other than the Euro, the annual average of the foreign exchange buying rates announced by the Central Bank of Turkey for the accounting period preceding the reported accounting period shall be taken into account in calculating the limit of EUR 750 million.

The new rule states that MNE group members must now submit CbC reporting notifications electronically via the Digital Tax Office by the end of the sixth month after the fiscal year.

The multinational enterprise group, whose consolidated financial statements for the accounting period before the reported accounting period have not yet been established as of these dates, may apply for an additional period by notifying the Administration of this situation.

The Communiqué No. 5 was retroactively implemented on 1 September 2024.