Communiqué No. 5 amending the General Communiqué on Disguised Profit Distribution Through Transfer Pricing (No. 1) was published in Official Gazette No. 32695 of 17 October 2024.
The “Communiqué (No: 5) Amending the General Communiqué on Disguised Profit Distribution Through Transfer Pricing (No: 1)” was published in Official Gazette No. 32695 of 17 October 2024.
The Communiqué revises General Communiqué No. 1 on Disguised Profit Distribution Through Transfer Pricing to align it with Transfer Pricing Decree No. 8956 of 14 September 2024.
Accordingly:
- The expression “the month of June each year” in the first sentence of the ninth paragraph of the section entitled “7.4 – Country-by-Country Report” has been replaced with “the sixth month following the end of the accounting period to be reported”.
- “Example 4” relating to that change has been added to the Communiqué. The example explains that a company must submit its information for the reporting accounting period of 1 May 2023 – 30 April 2024 electronically through the Digital Tax Office by the end of the sixth month following the end of that period (that is, by 31 October 2024).
Change made to the first sentence of the ninth paragraph of the section entitled “7.4 – Country-by-Country Report”:
Newly added “Example 4”:
The reporting accounting period of (ABC) Inc., resident in Türkiye, is 1 May 2023 – 30 April 2024, and in the special accounting period of 1 May 2022 – 30 April 2023, the accounting period preceding the reporting period, the group’s consolidated revenue was EUR 800 million. (The threshold set for country-by-country reporting in Türkiye is EUR 750 million.) Accordingly, (ABC) Inc., as the ultimate parent entity, must submit the country-by-country reporting notification form electronically through the Digital Tax Office by the end of the sixth month following the end of the reporting accounting period. (ABC) Inc. must also complete the country-by-country reporting for the relevant period by the end of 30 April 2025.