THE COUNTRY-BY-COUNTRY REPORT WITHIN THE SCOPE OF TRANSFER PRICING DOCUMENTATION OBLIGATION MUST BE SUBMITTED TO THE ADMINISTRATION BY THE END OF 2025.

As is known, the procedures and principles for new transfer pricing documentation obligations were set out in the "Amendment Communiqué (Serial No. 4) to the General Communiqué on Disguised Profit Distribution through Transfer Pricing (Serial No. 1)".

Transfer pricing documentation obligations now consist of: General Report, Annual Transfer Pricing Report, Country-by-Country Reporting Notification Form, Country-by-Country Report, and Controlled Foreign Company and Thin Capitalization Form.

Country-by-Country Report:

The ultimate parent entity or surrogate parent entity of multinational enterprise groups whose total consolidated group revenue – as shown in the profit/loss statement of the consolidated financial statements for the fiscal period preceding the reporting period – is EUR 750 million or more and that is resident in Turkey shall prepare the country-by-country report and submit it electronically to the Revenue Administration by the end of the fiscal period following the reporting period.

For example: for the 2024 fiscal period, if the consolidated group revenue for 2023 was EUR 750 million or more, the country-by-country report for 2024 must be prepared and submitted electronically to the Administration by the end of 2025.

Country-by-Country Report contains three tables:

• Table 1 – Country-by-country breakdown of revenues, taxes and business activities (revenue, profit/loss before tax, income/corporate tax paid and accrued, capital, retained earnings, headcount, and tangible assets other than cash).
• Table 2 – List of all MNE group entities by country (name, country of incorporation if different from residence, and main line of business).
• Table 3 – Additional explanations needed in completing the tables.

Respectfully.