Services

Transfer Pricing and International Taxation Consultancy Services

overview

Transfer Pricing and International Taxation Consultancy Services

Our company provides services for the analysis of the transactions of institutions with related persons/institutions and the methods applied in these transactions, and the preparation of annual transfer pricing reports that must be submitted to the Financial Administration. The measures taken within the scope of BEPS were also accepted by Turkey and the triple reporting method was adopted.

Since the transactions of the institutions with the related persons/institutions must comply with the transfer pricing legislation, it is very important to regularly analyze and control these transactions.

In this context, the services provided by our experts, who are the best in their fields in Turkey, are briefly as follows:

  • Analysis of transactions with related parties
  • Examination of contracts and other documents and applications of transactions
  • Determination and analysis of transfer pricing methods used/should be used
  • Determination of precedent prices as a result of the analysis study
  • Preparation of the Annual Transfer Pricing Report
  • Evaluating the developments regarding the OECD’s BEPS implementation and the effects of these developments on the current transfer pricing system by examining them on a risk basis.
  • Annual reporting obligations
  • Transfer Pricing Due Diligence
  • Transfer Pricing Check-Up
  • Transfer Pricing Restructurings
  • Transfer Pricing Policy Studies
  • In-Group Service Analysis and Benefit Testing
  • Transfer Pricing Review and Settlement
  • Advance Pricing Agreements
  • Transfer Pricing and Customs Valuation

Transfer Pricing Documentation Services 

In this context;

  • Master Documentation (Master File)
  • Annual Transfer Pricing Report
  • Country-by-Country Reporting
  • Precedent Studies
  • Transfer Pricing Form Studies are carried out.

Our International Taxation Consultancy Services

Turkey already has agreements with nearly 90 countries. Our services within the scope of international taxation, including Double Taxation Agreements, are basically;

  • Permanent Workplaces (PE)
  • Intangible Rights and Royalty Payments
  • Dependent Activities and Fees
  • FATCA and Common Reporting Standards
  • It consists of Double Taxation and Mutual Agreement Procedure.

Within the scope of our expertise in international taxation, services are also offered in the following areas:

 

  • Interest and dividend payments
  • Shipping, air, and land transport
  • Capital appreciation gains
  • Self-employment activities
  • Payments to executives
  • Payments to artists and athletes
  • Pensions and regular payments
  • Other income

International Company Structuring Services

Our services regarding international company restructurings:

  • Determination of company restructuring models for Turkey and abroad and tax and financial analysis of these models
  • Reconstruction and implementation of an international company and holding structures
  • Reconstruction and implementation of international finance and royalty structures
  • Optimization and development of current international tax strategies for investments in Turkey and abroad
  • Tax Effective Supply Chain Management in the operational restructuring process
  • Consultancy on international tax and transfer pricing in international mergers and acquisitions

Our International Investment Advisory Services

We provide the following services within the scope of our international investment consultancy.

  • Country and sector researches regarding the investment to be made abroad
  • Incentive consultancy for foreign investments
  • Determination and development of necessary strategies, including taxation, for investments made abroad
  • Design and implementation of an international company and holding structures
  • Establishment and implementation of international financing and royalty structures
  • Consultancy in foreign company acquisitions