Transfer pricing and Turkey implemantation

Transfer pricing, has become the most important tax issue as a result of integration of world economy, deepening globalalization an expantion of international trade volume. January 1st, 2007 marks the beginning of formal transfer pricing practice in Turkey by the way of article 13 of Turkish Corporate Tax Law (numbered 5520) under the title ?Disguised Income Distribution Through Transfer Pricing.? According to Article 13 of the Law, If a taxpayer enters into transactions regarding sale or purchase of goods and services with related parties, where the prices are not set in accordance with the arm?s length principle, then related profits are considered to be distributed in a disguised manner through transfer pricing. Turkish transfer pricing rules are mainly based on the OECD Transfer Pricing Guidelines.In this study we discussed transfer pricing from both positive and negative perspectitives within the framework of Corporate Income Tax Law, the OECD regulations, and other related laws. The study concludes that the current transfer pricing regulations are prepared by taking into account international developments and particulary the OECD Transfer Pricing Guidelines.