Post by account_disabled on Mar 16, 2024 5:36:13 GMT -5
The Revenue Administration electronically. CbCR shall include the following information for each country where a MNE operates Revenue ProfitLoss Before Tax Paid Income TaxCorporate Tax Accrued Income TaxCorporate Tax Capital Accumulated Earnings Number of Employees Tangible Assets other than Cash and Cash Equivalents The title of each business residing in the relevant country the name of the country and main activities of each business information on whether the country where the business is established is different from its tax residency.
The Turkish resident companies of a MNE Group shall submit CbCR to Revenue Administration in the case that the country where ultimate parent company is resident does not require CbCR it does not have an effective competent authority agreement with Turkey or systematic errors occur. The Turkish resident companies of a MNE Group shall submit CbCR to B TO B Database Revenue Administration in the case that the reporting company is surrogate entity and the relevant country has no competent authority agreement with Turkey or systematic errors occur. The first CbCR of the taxpayers will be prepared for the financial year and will be submitted until . Companies having special accounting period will prepare their first CbCR for the accounting period starting after January and submit it until twelve months after the end of their accounting period for.
Our Evaluations The Presidential Decree introduces new documentation requirements for the Multinational Companies related to transfer pricing rules. It also envisages that the tax loss penalty will be applied at a discount for the taxes not accrued in time or not accrued completely within the scope of Disguised Profit Distribution through Transfer Pricing if the documentation requirements are fulfilled fully and on time. In this context timely fulfillment of transfer pricing documentation requirements by Multinational Companies will both be a protection shield for these companies and allow benefiting reduced penalty rates if the transactions are considered as against the arms length principle.
The Turkish resident companies of a MNE Group shall submit CbCR to Revenue Administration in the case that the country where ultimate parent company is resident does not require CbCR it does not have an effective competent authority agreement with Turkey or systematic errors occur. The Turkish resident companies of a MNE Group shall submit CbCR to B TO B Database Revenue Administration in the case that the reporting company is surrogate entity and the relevant country has no competent authority agreement with Turkey or systematic errors occur. The first CbCR of the taxpayers will be prepared for the financial year and will be submitted until . Companies having special accounting period will prepare their first CbCR for the accounting period starting after January and submit it until twelve months after the end of their accounting period for.
Our Evaluations The Presidential Decree introduces new documentation requirements for the Multinational Companies related to transfer pricing rules. It also envisages that the tax loss penalty will be applied at a discount for the taxes not accrued in time or not accrued completely within the scope of Disguised Profit Distribution through Transfer Pricing if the documentation requirements are fulfilled fully and on time. In this context timely fulfillment of transfer pricing documentation requirements by Multinational Companies will both be a protection shield for these companies and allow benefiting reduced penalty rates if the transactions are considered as against the arms length principle.