Turkey: Draft guidelines on advance pricing agreements

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Turkey: Draft guidelines on advance pricing agreements

askin.jpg

Devrim Askin

Turkish Revenue Administration (TRA) recently published draft guidelines on advance pricing agreements (APAs) with the aim of informing corporate taxpayers planning to apply for an APA. In this context, the draft guidelines provide information regarding:

  • definition, scope and duration of APA;

  • APA process which consists of five steps (pre-filing, formal application, preliminary evaluation, analysis, and unconditional/conditional acceptance or rejection of the application);

  • preparation of annual APA report for monitoring the implementation of the signed APA; and

  • revision, renewal and cancellation of an existing APA.

In fact, the draft guidelines reiterate the explanations already made in the existing transfer pricing legislation, particularly the provisions contained in the Transfer Pricing General Communiqué No.1. However, more specific information is requested by TRA from taxpayers in their APA application than those listed under section 7.2 of the above-mentioned General Communiqué No.1, including:

  • function-risk matrix between related parties;

  • flow chart of all intercompany transactions;

  • information on the type of intangibles (patent, trademark, know-how, industrial design and so on) related to the transaction covered in the APA;

  • information on (if any) R&D activities that are carried out by the Turkish entity;

  • critical assumptions regarding functions, financial issues, accounting practices, economic conditions, legal regulations and any other related matters;

  • (if any) relevant tax audit reports;

  • any other APAs applied for, or concluded, by the foreign related parties;

  • any transfer pricing documentation prepared by the foreign related parties involving in the intercompany transaction that is the subject matter of APA;

  • (if any) relevant cost contribution agreements; and

  • (if any) all relevant agreements between related parties; and

  • provision of financial statements according to Turkish GAAP [generally accepted accounting principles].

It can be said that such informative guidelines are beneficial for taxpayers intending to request an APA to ensure that the APA process is carried out by TRA in a transparent and cooperative environment.

On the other hand, it would be appropriate to review the scope of information to be submitted in the APA application in order not to create any additional burden on taxpayers and to make more explicit explanations regarding comparable searches, comparability adjustments, financial analyses and critical assumptions so that taxpayers, to the extent possible, can prepare their application files more completely and hence the APA process can be concluded in a timely and efficient manner.

Last but not least, there is no specific date given by TRA as to when the draft guidelines will be completed and published as a final version. In this context, TRA may provide an insight about the expected date for the relase of final guidelines after receiving public comments.

Devrim Askin (devrim.askin@tr.pwc.com)

PwC Turkey

Tel: + 90 212 326 6662

Website: www.pwc.com.tr

more across site & shared bottom lb ros

More from across our site

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires
Gift this article