Canan Aladag Establishing a transfer pricing policy over intra-group services may seem quite easy to accomplish, but it often requires a decision to be made about being precise and pragmatic, while there are non-TP impacts that should also be considered. Under Turkish transfer pricing rules, detailed documentation showing the calculation of the service charge, applying a mark up rate that is in line with the arm's-length principle and actual provision of the services by related parties, must be provided, which is pretty much in line with section 7.6 of the OECD guidelines (and BEPS draft section 7.7).
September 28 2015