Post by account_disabled on Mar 16, 2024 7:29:30 GMT
The addresses related with APA Other important subjects After completing the process and finalising an APA the tax administration will not be able to challenge the method used by taxpayer provided that taxpayer doesnt violate the clauses of agreement. However the APA process may last for years because of reasons such as the complexity of business life and the difficulty to establish adequate information promptly. For this reason to prevent these kinds of problems it is very helpful for taxpayers if they submit adequate documents and information as requested by tax administration.
If the Turkish tax authorities conclude having assessed the taxpayers request for an APA that relatedparty transactions have links with other jurisdictions it can decide to negotiate a bilateral or multilateral APA with the competent authority or authorities and if a tax treaty exists between Turkey and its partner state. Documentation for APAs The basic information B TO B Database and documents that taxpayers who request an APA should present to the tax administration are Written application the requested period of arrangement names Republic of Turkey ID numbers addresses and telephone numbers of taxpayers or their representatives who will be involve in the arrangement.
Process taxpayers line of business structure of organisation headquarter and branches shareholders capital structure sector summaries of economic and legal background definitions of related parties and ownership relations of related parties should be stated in written application All information related to the functions risks of corporation and assets that are used Documents and reasons related to critical assumptions suggested transfer pricing method and explanations analysis and other works based on the choice and application of this method The information related to intangible property ownership and payments of royalty or intangible rights If the related parties use different accounting standards and methods the information related to these standards and methods The price list at the fiscal period of the application date The cost of production at the fiscal period of.
If the Turkish tax authorities conclude having assessed the taxpayers request for an APA that relatedparty transactions have links with other jurisdictions it can decide to negotiate a bilateral or multilateral APA with the competent authority or authorities and if a tax treaty exists between Turkey and its partner state. Documentation for APAs The basic information B TO B Database and documents that taxpayers who request an APA should present to the tax administration are Written application the requested period of arrangement names Republic of Turkey ID numbers addresses and telephone numbers of taxpayers or their representatives who will be involve in the arrangement.
Process taxpayers line of business structure of organisation headquarter and branches shareholders capital structure sector summaries of economic and legal background definitions of related parties and ownership relations of related parties should be stated in written application All information related to the functions risks of corporation and assets that are used Documents and reasons related to critical assumptions suggested transfer pricing method and explanations analysis and other works based on the choice and application of this method The information related to intangible property ownership and payments of royalty or intangible rights If the related parties use different accounting standards and methods the information related to these standards and methods The price list at the fiscal period of the application date The cost of production at the fiscal period of.