A comparative research concerning the implementation of the hidden profit sharing by using transfer pricing in turkey and OECD countries

The international economical relations which were appeared as a result of the liberalization movement in the global economical system obligated the countries to update their tax systems.The point of transfer pricing is a subject that may effect the company profits, might supply the government income optimal level, in the interior and exterior country platform, able to causes harmful tax rivalry and it has affects on corporate management, investment decisions and commercial decisions. Turkey has revised the faults of the present organizing, too. With the Corporation Tax Law numbered 5520 which was become valid in 2006, the subject of hidden profit sharing was developed and elaborated. Thus, it was wanted to interfere the diminishing tax base, at the same time it was tried to comply international regulations.While the subject of hidden profit sharing was adopting to the present-day, it was utilized the principles that OECD had developed. However there were regulations could never be adapted to Turkish circumstance and also there were mistaken and wrongly transferred regulations.The retardation of adapting the OECD regulations, modeled to most of the countries, to the Turkish Tax System, performing it without informing, education, infrastructure caused tax-payers and tax controllers fail. Complexity between the new notions in a short time causes difficulties for implementation.