Distribution of hidden profits by means of transfer pricing and its practice in Turkey

In this study; the article that is for the Distribution of Hidden Profits by Means of Transfer Pricing; as in the law nr. 5520 on Corporation Tax, is explained, the impact of the court decisions on the legislation is examined. While making the subject explanations, in the first section the historical development of the transfer pricing on world scale is examined with the theoretical infrastructure of the conceptions. In the second section the regulations in Turkey about the Hidden Profit Distributions by Means of Transfer Pricing is probed, the implementation base in the related article of the Law nr. 5520 on Corporation Tax is explained and by detecting the renovations on the institution of hidden profits, the place of the hidden profits distribution concept in Corporation Tax Law 5422 is compared to that of the Corporation Tax Law nr. 5520. In the last section stress is laid on the legal dimensions of the implementation of the Hidden Tax Distribution practices in Turkey and The decisions given by the Council of the State are examined form the point of the interpretations and its impacts on the transactions as the law is practiced by the administration.