Post by account_disabled on Mar 16, 2024 4:24:41 GMT -6
The who have kinship in the direct line and collateral kinship including the third degree and kinship by marriage will continue to be evaluated as related persons. In addition the Presidential Decree adds a new requirement for the situations that can be determined as the disguised profit distribution. As per the legislation real or legal persons directly or indirectly holding minimum of shares voting rights or dividend rights of a company will be considered as a related party.
Master File Corporate taxpayers who are affiliated with MNEs whose asset size in the balance sheet and net sales in the income statement for the previous fiscal period are both TL million and above have been obliged to B TO B Database prepare a master file. In this context the issues related to the master file adopted within the scope of the OECD BEPS project are also adopted by our legislation. Accordingly a master file should include the following subjects Organizational Structure of the MNE Definitions of Business Activities Intangibles Owned Intragroup Financial Transactions Financial and Tax Status According to the Presidential Decree the first master file of the taxpayers will be prepared for the financial year.
Companies having special accounting period will prepare their first master file for the accounting period starting after January . Country by Country Reporting CbCR Mutual Administrative Assistance Agreement in Tax Matters which is signed by Turkey provides the legal basis for the exchange of information among the countries. In the context of this Agreement the CbCR requirements of OECD entered into force in Turkey. Accordingly the ultimate parent company of a MNE Group resident in Turkey which has total consolidated group revenue of Euro Million or above for the accounting period of the previous fiscal year to the reporting year shall prepare CbCR until the end of the next twelvemonth period after the end of the reported fiscal year and submit to the.
Master File Corporate taxpayers who are affiliated with MNEs whose asset size in the balance sheet and net sales in the income statement for the previous fiscal period are both TL million and above have been obliged to B TO B Database prepare a master file. In this context the issues related to the master file adopted within the scope of the OECD BEPS project are also adopted by our legislation. Accordingly a master file should include the following subjects Organizational Structure of the MNE Definitions of Business Activities Intangibles Owned Intragroup Financial Transactions Financial and Tax Status According to the Presidential Decree the first master file of the taxpayers will be prepared for the financial year.
Companies having special accounting period will prepare their first master file for the accounting period starting after January . Country by Country Reporting CbCR Mutual Administrative Assistance Agreement in Tax Matters which is signed by Turkey provides the legal basis for the exchange of information among the countries. In the context of this Agreement the CbCR requirements of OECD entered into force in Turkey. Accordingly the ultimate parent company of a MNE Group resident in Turkey which has total consolidated group revenue of Euro Million or above for the accounting period of the previous fiscal year to the reporting year shall prepare CbCR until the end of the next twelvemonth period after the end of the reported fiscal year and submit to the.