Key issues of Turkish advance pricing agreements
October 08, 2008
Ramazan Biçer, senior transfer pricing specialist in the transfer pricing division of the Turkish revenue administration, highlights the key issues of advance pricing agreements in Turkey
Advance pricing agreements (APAs) are defined by the OECD transfer pricing guidelines for multinational enterprises and tax administrations as an appropriate set of criteria (for example transfer pricing method, comparables and appropriate adjustments thereto, critical assumptions as to future events) for the determination of the transfer pricing for those transactions over a fixed period of time in advance of controlled transactions. Generally, an APA means a process which is started by the application of taxpayers and carried on with the negotiations between taxpayer and/or its related party (or parties) and tax authority (or authorities) to resolve transfer pricing issues arising with related party transactions.
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