Tax, Accounting & R&D
The arm's-length study, the annual file, and the form filed with your corporate-tax return. Built to OECD and Article 13 standards so the Revenue Administration finds nothing to adjust.
What it is
Every transaction between your Turkish LTD and a related foreign entity (service fees, royalties, intercompany loans, cost recharges, asset transfers) has to be priced at arm's length under Article 13 of Corporate Tax Law No. 5520. The standard tracks the OECD Transfer Pricing Guidelines (latest 2022 version). The Revenue Administration looks at three things during an examination: the price was set by an accepted method, the method was supported by comparables, and the documentation existed at the time of the transaction, not reconstructed afterward. Mispriced flows are reassessed with corporate tax plus a 50% transfer-pricing penalty plus statutory interest. We deliver the inventory, the benchmarking, the Master File and Local File where required, and the annual transfer-pricing form filed with your corporate-tax return. Studios above the multinational threshold also get the Country-by-Country Report.
The documentation stack
The annual form is mandatory for any Turkish company with a related-party transaction. The other three layers turn on group size and cross-border activity. We assemble what you need and not more than you need.
Transfer Fiyatlandırması Formu
Yıllık Transfer Fiyatlandırması Raporu
Genel Rapor
Ülke Bazlı Rapor
Penalty math
When the Revenue Administration adjusts an intercompany price, the gap between the declared price and the arm's-length price becomes additional taxable income. Corporate tax is charged on the gap at the prevailing rate. A 50% transfer-pricing penalty is added (a reduced rate compared with the 100 to 300% general tax-loss penalty, but still meaningful). Statutory interest (gecikme faizi) accrues from the original due date. Documentation that existed at the time of the transaction is what shields you. Reconstructing it afterwards is not the same.
Reassessed tax
Corporate tax on the price gap at the 25% rate (30% for financial institutions).
50% penalty
Transfer-pricing penalty on the underpaid amount, reduced from the general 100 to 300% range.
Statutory interest
Gecikme faizi from the original due date until payment of the assessment.
How we do it
The first year is the heavier lift. Subsequent years refresh the benchmarking and update the file.
Transaction inventory
Every related-party transaction inventoried: development services to HQ, royalty payments out, intercompany loans, cost recharges (cloud, software licences, shared employees), asset transfers, intra-group guarantees. Each line tagged with counterparty, currency, and contract.
Method selection
The right OECD method picked for each transaction type. Cost-plus under TNMM for routine development services (the typical pattern for a Turkish dev house billing a foreign HQ). Comparable Uncontrolled Price (CUP) for royalties where third-party licence benchmarks exist. Profit split for highly integrated value chains. The reasoning is documented so a Revenue Administration auditor can follow it.
Database benchmarking
Comparable-company search in Amadeus, Orbis, or comparable databases. Geographic and sector filters applied. Comparability adjustments (working-capital, functional, risk) documented. Arm's-length range computed (typically inter-quartile range). For royalties, third-party software-licence rates pulled from royalty databases.
Local File (Yıllık Rapor)
The full Local File assembled to the Turkish General Communique standard: industry analysis, group structure, controlled transactions, functional and risk analysis, economic analysis, methodology, and conclusions. Delivered in Turkish (or bilingual where the group reports in English).
Master File and CbCR (where applicable)
Master File prepared for groups above the relevant Turkish thresholds (large multinationals with consolidated revenue and asset tests). Country-by-Country Report coordinated for groups with consolidated revenue at or above EUR 750M.
Annual transfer-pricing form
Form 1 (Transfer Fiyatlandırması Formu) prepared and filed with your annual corporate-tax return by 30 April. The form is mandatory for every Turkish company with related-party transactions, regardless of size. Filing it correctly is what immunises you from the heaviest penalties.
What's included
Key facts
Bundled in
Pricing
Included in Enterprise. Standalone: from USD 9,500 for a single-jurisdiction Local File and the annual form. Master File and CbCR scoped separately.
Related services
The intercompany agreements that move IP and revenue between your HQ and the Turkish entity. Arm's-length, bilingual, treaty-aware, and designed to keep the service-export exemption clean.
Decide who holds the shares of your Turkish company. A person, another company you own, or Turquo on your behalf.
Türkiye's headline incentive for foreign-facing software and gaming studios: a 100% corporate-tax exemption on qualifying service-export income under Article 10/1-ğ. The contract structure, banking flow, and bookkeeping designed to qualify every year, not just the first.
Free 30-minute discovery call. We'll match the right services to your stage and come back with a fixed-fee proposal.
