Transfer Pricing Turkey

Innovative Business Mind on Transfer Pricing Risk Assessment, Planning and Management

Why Transfer Pricing?

International business taxation and transfer pricing is at the top taxation agenda for not only multinational companies, but also governments. Transfer pricing is the price or amount at goods or services, tangibles or intangibles transferred/bought/sold between related parties/persons or associated enterprises.
In case, transfer pricing does not reflect market forces, free market prices and the arm's length principle, the tax liabilities of the associated enterprises and the tax revenues of the host countries could be distorted via transfer pricing. Governments need to ensure that the taxable profits of multinationals have not been manipulated and the profits are not distributed in a disguised manner via transfer pricing. However, multinationals are often faced with risks of double taxation sourced from the determination of arm’s length remuneration for their cross-border transactions with related enterprises. Transfer pricing does not necessarily mean that profit distribution in disguised manner via transfer pricing.
As a result of increased knowledge sharing and harmonisation studies among the world-wide tax authorities, and audit scrutiny by the national tax authorities; it is vital to multinational companies to implement accurate, consistent and defensible optimal transfer pricing/advance pricing policies and procedures as well as effective tax planning, valuation and risk management complied with the transfer pricing rules.

As a “complex tax rate optimisation work” at the core, transfer pricing always exposures financial risks which may lead to rather costly cross-border disputes with world-wide tax authorities. There are always similar Transfer Pricing risks for domestic group or holding companies of all sizes.

International Taxation and Transfer Pricing Services practice of GRANIT are based on deep tax knowledge and expertise, innovative business mind on assessment, planning and management risks (ERM) creating high level real value for multinationals, holding companies and group companies of all sizes.

GRANIT is an independent Turkey global partner of Transfer Pricing Associates, a leading global professional network providing global transfer pricing solutions over ten years of international experience.


Transfer Pricing Services of GRANIT include;

  • Assessment, planning and management of national and/or international Transfer Pricing risks,

  • Functional Analysis for organisations, operations, related persons, functions, facts, risk and asset profile settings,

  • Economic Analysis/Benchmarking to identify the arm’s length range,

  • Reviewing, designing and implementation of all intra-group service charges, whether cost based or value based, “incremental cost/tax” on the transactions, cost sharing arrangements for research and developments, management fees, intangible assets, licensing of patents, know-how, trademarks, trade names and other intangibles,

  • Reviewing, designing and implementation of all intra-group charges for manufacturing, sourcing, distribution and other operations,

  • Reviewing and implementation of prevention of double taxation of bilateral treaties, customs valuation and tax valuation,

  • Calculation and creating optimal transfer prices and tax structures, assessment of the best transfer pricing method proven,

  • Transfer Pricing documentation and certification to support national and/or global compliance requirements of Treasuries and/or Ministries of Finance,

  • Transfer Pricing Report vs. Advance Pricing Agreements with single or multiple tax authorities, analysis, applications and negotiations,

  • Supporting dispute solution and reconciliation for transfer pricing tax audits not only in Turkey, but also  in other jurisdictions, and providing litigation support for cross-border transfer pricing disputes,

  • Designing and monitoring of implementation of national and/or global transfer pricing systems based on assessment, planning and management of national and/or international Transfer Pricing risks,

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