Evaluating of transfer pricing matters on tax audits

The importance of transfer pricing in taxation has increased due to the spread of global businesses and the economy recently. Transfer pricing is used as a tax avoidance tool by multinational enterprises, causing a loss in tax revenues of the states' treasuries. At the international level, the field of transfer pricing has been one of the most comprehensive and worked tax issues. In Turkey, transfer pricing has a comprehensive implementation area in terms of tax legislation and tax audit. The subject of transfer pricing has been examined in the literature in terms of its legislation and implementation, but it has not been researched how it has been criticized in tax audits. In this thesis, questions such as how transfer pricing is interpreted by the tax administration, how the accounting system is used, how the audit authority is structured, how risk analysis is applied to taxpayers are evaluated. These studies were carried out by examining real tax audit cases. From the tax audit reports, only the determinations and evaluations about transfer pricing are included in the thesis by complying with the privacy and confidentiality rules. Thus, transfer pricing is investigated for the first time in terms of accounting, auditing, administrative structure and legal interpretation through real audit cases. The issues identified as a result of the research were concluded with recommendations. Transfer pricing audits should be classified according to their technical dimension.