Why this catches foreign-owned companies
If your Turkish entity buys from, sells to, borrows from, pays a management fee to or receives a service from anyone in your group, you have related-party transactions. Turkish law requires them to be priced at arm's length and requires you to be able to prove it.
The trap is the timing. The annual transfer pricing report is not filed with anything. It must simply exist by the corporate tax return deadline, and it is produced only when the administration or an inspector asks. Nobody chases you for it. Then an inspection opens three years later, the report is requested, and a document that should have been written contemporaneously has to be reconstructed from memory — if it can be produced at all.
Who has to document what
| Your entity | Transactions that must be documented |
|---|---|
| Registered with the İstanbul Büyük Mükellefler Vergi Dairesi | Domestic and cross-border related-party transactions |
| Any other corporate taxpayer | Cross-border related-party transactions |
| Operating in a free zone | Domestic related-party transactions |
| All corporate taxpayers | Transactions with your own foreign branches, and with related parties in free zones |
There is no monetary threshold that exempts you from the report. Having in-scope transactions is the trigger.
The four obligations
1. Annual transfer pricing report. Prepared by the corporate tax return deadline, held on file, submitted on request. For the 2025 financial year that date was 30 April 2026.
2. The form attached to the corporate tax return. Every corporate taxpayer with related-party transactions in the period files it with the return. Goods and services transactions with a related party totalling under TRY 30,000 net for the year need not be listed — purchases and sales tested separately. Failure to file carries penalties under the Tax Procedure Law.
3. Master file (genel rapor). Required where you belong to a multinational group and, in the preceding period, your balance sheet total assets and net sales were each TRY 500 million or more. Both tests must be met. Due by the end of the following accounting period.
4. Country-by-country reporting. Applies where consolidated group revenue reached EUR 750 million. The report is filed by the Turkish ultimate parent or a designated surrogate through BTRANS by the end of the twelfth month after the reported period. The separate notification form is due within six months of the year end — for calendar-year taxpayers, 30 June.
What we do
We prepare the report as a working document rather than a filing exercise: functional analysis of what your Turkish entity actually does, selection and justification of the method, benchmarking, and the intercompany agreements that have to match it. Where your group already has a master file, we align the Turkish local file to it instead of writing something that contradicts it — a mismatch between the two is one of the first things an inspector looks for.
We also tell you when a policy will not survive scrutiny. A cost-plus margin your group applies everywhere may be indefensible in Türkiye if the local entity carries risks the margin does not reflect.