International Tax Bulletin: 23.12.2021/21
Country-By-Country Reporting (CbCR) For The 2020 Accounting Period Should Be Submitted to The Administration Electronically via The BTRANS System Until 31.12.2021
The Presidential Decree No. 2151, which was published in the Official Gazette dated 25.02.2020 made significant changes in the transfer pricing legislation.
In this scope, Country-by-Country Reporting ("CbCR") obligations were imposed within the framework of the three-tiered transfer pricing documentation adopted within the scope of OECD BEPS. Our explanations on the subject were included in the Guide we prepared in the form of a Question and Answer.
“General Communiqué No 4 on Disguised Profit Distribution Through Transfer Pricing” was published on the Official Gazette dated 01.09.2020. The issues determined by the Presidential Decree were fully reflected in the said Communiqué.
In the Communiqué, it is explained that the Country-Based Report consists of 3 tables: Table 1 - the distribution of income, taxes and other consolidated financial data by country, Table 2 - the activities of all enterprises included in the MNEs, and Table 3 - additional explanations.
In addition, it is stated in the communiqué that the MNEs with a total consolidated group income of 750 million Euros and above, according to the consolidated financial statements of the previous accounting period, has a CbCR obligation. The CbCR must be submitted to the Administration in electronic form until the end of the twelfth month after the accounting period reported by the ultimate parent or surrogate entity residing in Turkey.
In this context, CbCR for the 2020 accounting period should be submitted to the Administration electronically via the BTRANS System until 31.12.2021.