Advance pricing agreements in Turkey

Turkey introduced transfer pricing legislation and an advance pricing agreement (APA) procedure for the first time in the new Corporate Income Tax Act 5520 of 21 June 2006 (hereinafter: the Act). Although the transfer pricing legislation entered into force on 1 January 2007, the APA procedure generally applies from 1 January 2008. This note examines and clarifies the procedural rules of the new APA regime that are contained in the Act.