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

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
Gift this article