Publications, Articles, News
TAXATION of MULTINATIONALS and TRANSFER PRICING
(Turkish)
Author: Murat Tenekecioglu
Will be at bookstores soon!
INTERNATIONAL BUSINESS TAXATION and TRANSFER PRICING
(English)
Author: Murat Tenekecioglu
Will be at bookstores soon!
Globalisation creates international business and investment opportunities for enterprises of all sizes so that the word multinationals does not necessarily mean “conglomerates” anymore.
International business taxation and transfer pricing is at the top agenda of taxation for not only multinationals, but also governments.
Transfer pricing is the price at goods or services, tangibles or intangibles transferred between associated or controlled 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. Transfer pricing does not necessarily mean profit distribution in disguised manner via transfer pricing. In addition to this, multinationals are often faced with risks of double taxation sourced from the determination of arm’s length remuneration for their cross-border transactions with associated enterprises.
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 crucial to multinationals to implement not only accurate, consistent and defensible optimal transfer pricing or advance pricing policy and procedures, but also effective tax planning, valuation and risk management complied with the transfer pricing rules of different countries.
As a “complex tax rate optimisation work” at the core, transfer pricing always exposures financial risks on international businesses, and may lead to rather costly cross-border disputes with world-wide tax authorities.
International business taxation and transfer pricing tightly depend on deep local and international tax knowledge and expertise combined with sound knowledge of economics, finance, commercial code, and doing business.
The goal of this study is to highlight taxation and transfer pricing problems of multinationals by taking into account of the organisational structures, functions, economic transactions and their effects for better understanding of international business taxation and transfer pricing theory and practices.
Who is Murat TENEKECİOGLU?
MURAT is an Economist and a Sworn Fiscal Advisor. He was graduated from Political Sciences Faculty of Ankara University, and has M.A. degree on Economics of Public Policy at University of Leicester (England). He also carried out a one year study on Taxation of Multinationals and Transfer Pricing in England.
MURAT has twenty six years of professional experience balanced in both private sector and public. He is a Former Head Inspector of Finance at Ministry of Finance, Member of the Board of Auditors at TMSF/BDDK Banks, Ex-Head of Department at Prime Ministry Privatization Administration, Former Member of Board at both Zinc Manufacturing Inc. and Soma Power Generation Inc. He also served as Deputy Project Manager for World Bank supported Development of the Turkish Public Finance Administration Project, and also as Ex-Vice President at a private management consulting company.
MURAT represented Hydro Quebec International (Canada) and some of the UK based international business associations in Turkey.
MURAT published numerous articles on business, finance, taxation and economics.
MURAT is a Member of the Management Consulting Association, and Chamber of Istanbul Certified Public Accountants as well.
