“There have been lots of transfer pricing audits in Turkey this year so taxpayers will welcome the MAP,” said Metin Duran, transfer pricing partner at KPMG.

It is not only domestic clients that are eager to see how the guidelines will develop the system.

“A lot of international companies have been asking if the MAP is available in Turkey,” he added.

“Some clients have already applied for MAPs in relation to transfer pricing,” said Zeki Gündüz, transfer pricing partner at PricewaterhouseCoopers.

None have been concluded yet, though as MAPs are a relatively new development in Turkish tax law, this is unsurprising.

“We have no experience of MAPs yet and there is no binding requirement if no conclusion is reached. We do not have the arbitration process in Turkey,” Gündüz said.

The MAP is an option for taxpayers who think that the enforcement of tax assessments in one country, including those relating to transfer pricing, would be incorrect under the terms of a double tax treaty.

Using the procedure taxpayers may choose to resolve the issue by sharing information with its own competent authority and ask for a bilateral agreement between the two tax authorities.

The guidelines aim to prevent misinterpretations between the tax authorities and the taxpayer. Theyfollow the OECD guidelines closely, though there are some differences.

“If you apply for the MAP you can’t go to court and if you have already applied to court you must withdraw the application before applying for the MAP. Some countries have different rules,” said Duran.

The problems don’t always relate to domestic issues. Dealing with competent authorities in other countries can be tough.

“Some countries that Turkey deals with have difficult tax authorities, for instance Kazakhstan and Albania,” said Gündör.

In dealing with these countries, taxpayers may prefer to resolve their issues through the courts rather than use the MAP.

Turkey has an extensive network of 71 double tax treaties so there certainly is scope for the use of the MAP.