Subject: The first unilateral Advance Pricing Agreement in Turkey was signed between the Turkish Revenue Authority and the relevant corporate taxpayer on July 15th, 2011.
A The first unilateral Advance Pricing Agreement (APA) was finalized and signed between the Turkish Revenue Authority (TRA) and the relevant Turkish corporate taxpayer on July 15th, 2011.
As a reminder; starting from 1 January 2009 it is possible for all Turkish corporate taxpayers to apply for unilateral, bilateral and multilateral APAs with regard to their cross-border related party transactions. APA term of agreement is three years (maximum).
Those corporate taxpayers in Turkey having related party transactions with corporate taxpayers operating in Turkish Free Trade Zones are also eligible to apply for APA starting from 1 January 2009 with respect to such related party transactions.
APA filing fee is TL 33,171.60 for 2011. The fee for renewal is also fixed as TL 26,537.20 (valid for 2011). The amounts are subject to change every year.
If you would like to review the official announcement of the TRA with regard to the conclusion of the first APA in Turkey, you can click here to review the announcement (in Turkish).
We believe that this is a good start and hope that it would pave the way for negotiations regarding bilateral APAs in the near future.
Please feel free to contact our Transfer Pricing service line team in case you need further information about the APA process in Turkey.
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