International Tax · Transfer Pricing
Transfer pricing local file (Ülke Dosyası)
If your Turkish entity has related-party transactions — management fees, royalties, intercompany sales, intra-group financing — Turkish law requires an annual local file. We prepare it in OECD + Turkish Ministry of Treasury format.
Who this is for
- Turkish subsidiaries of foreign groups with intercompany management services
- Licensing arrangements with foreign parent (royalty, IP)
- Intra-group financing or cash-pool arrangements
- Taxpayers registered with the Large Taxpayers Office (automatic scope)
What's included
- Related-party transaction mapping and materiality assessment
- Functional analysis (functions, assets, risks per entity)
- Benchmarking study with appropriate comparables database
- Method selection (CUP, RPM, CPM, TNMM, profit split) with justification
- Full local file document in Turkish + English executive summary
- Coordination with group master file where applicable
Scope & SMMM disclosure
We deliver the full engagement under SMMM (Certified Public Accountant) scope — preparation, filings, advisory, and ongoing compliance. For YMM certification reports, statutory audits, and court representation we coordinate with vetted partners. You get one point of contact and one invoice.
Frequently asked questions
Who needs a local file in Turkey?
Taxpayers with related-party transactions above the annual threshold must prepare one each year. Scope widens for Large Taxpayers Office registrants and Turkish subsidiaries of foreign groups.
When is the filing deadline?
The local file must be ready by the corporate tax return deadline and submitted upon request from the Turkish tax authority.
Related services
Open a Turkish branch or subsidiary of your foreign company
Branch, subsidiary, or liaison office — we walk you through the trade-offs and run the full setup. Three structures, three tax regimes, three exit paths. We pick the right one before we file.
Learn more →Thin capitalization analysis (örtülü sermaye)
When a Turkish company borrows from related parties above a 3:1 debt-to-equity ratio, interest on the excess is treated as disguised capital — non-deductible and, in some cases, re-characterized as a hidden dividend. We check your structure before the tax office does.
Learn more →Ready to start?
Book a free 20-minute call. We scope your situation and give you a clear fixed-fee quote.
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