Turkey Transfer Pricing Documentation Requirements
Turkey requires a Local File from every resident entity with cross-border related-party transactions, with no threshold, and a Master File from groups whose Turkish entities exceed asset and turnover tests. Documentation that is prepared properly and on time halves any transfer pricing penalty.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Asset value ≥ TRY 500m and turnover ≥ TRY 500m in the prior year | By the Master File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | TR | Yes (special irregularity penalty; 50% reduction for timely documentation) |
Local File Required | All resident entities with cross-border related-party transactions (no threshold) | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | TR | Yes (special irregularity penalty; 50% reduction for timely documentation) |
Disclosure form Annual filing | Taxpayers with related-party transactions (domestic and cross-border) | With the CIT return (by 30 April) | Submission deadline The documentation must be filed with the tax authority by the date shown. | TR | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Turkey deadline
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Scope of the documentation obligation
The Local File obligation in Turkey is not gated by a threshold: every entity that is tax resident in Turkey and has cross-border intercompany transactions must hold a Local File. The Master File applies to companies that are part of a multinational group where the Turkish entities meet both an asset value of at least TRY 500 million at the close of the previous year and a turnover of at least TRY 500 million. Documentation is produced within 15 days of a request, and a transfer pricing disclosure form is filed with the corporate tax return.
Distinctive features of the Turkish regime
The defining feature of the Turkish regime is the penalty-reduction incentive. Documentation that is prepared properly and submitted on time eliminates 50 percent of any tax penalty raised in a transfer pricing assessment, so timely compliance carries a direct and quantified benefit rather than only avoiding a documentation fine. Failure to prepare the Master File or to disclose the Local File attracts a special irregularity penalty, revised annually, and can itself trigger a tax audit. The disclosure form is notably broad, capturing all related-party transactions, both domestic and cross-border, regardless of magnitude. There is no safe harbour.
Benchmarking and comparables
Local comparables are preferred. Multi-year analysis is preferred. A fresh benchmarking search is preferred. The limitation period is five years.
Frequently asked questions
Does Turkey reward timely transfer pricing documentation?
Yes. Documentation prepared properly and submitted on time eliminates 50 percent of any tax penalty raised in a transfer pricing assessment, in addition to avoiding the irregularity penalty for non-compliance.
Is there a threshold for the Turkish Local File?
No. Every entity that is tax resident in Turkey and has cross-border intercompany transactions must hold a Local File. The TRY 500 million tests apply only to the Master File.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.