Transfer pricing in the associated people

Multinational companies that constitute their products in different countries emerge as a result of globalization. Then, their effort to increase their capital is caused to higher importance of transfer pricing. Transfer pricing is on of the important tax-related issue in Turkey as well as the World. In this work, the concept about related person who is related to distribution of concealed income via transfer pricing and problems of this concept application are examined that one of the important improvement on Turkish Taxation is brought by 5520 numbered new Institutions Tax Law. In this scope, the work is done by some developed countries, especially USA, European Union, and OECD countries are studied. Under favor of the new regulations of 5520 numbered new Institutions Tax Law, we say that Turkish tax regulation is almost equal to international regulation but definition of the related person who is related to distribution of concealed income via transfer pricing is left in very broad scope and this definition is caused some uncertainties. In conclusion, this regulation change is broadening scope of related person concept but when recommendations are considered in this work, making juridical and administrative arrangements could solve most of the problems on applications.