Subject: Circular on Disguised Profit Distribution via Transfer Pricing / 3 published on 22.02.2021 announces the extension of period for filing the first CbC report for 2019 that must be filed electronically via the tax administration’s information transfer system (BTRANS) and announces that correction of prior CBC notifications is not required.

As known, the period for the submission of the first CbC report for the 2019 fiscal period and the special fiscal period ending in January / 2020 through Circular TF-2 / 2020-1 dated 17/12/2020 through the Revenue Administration Information Transfer System (BTRANS) has been extended by the end of February 26, 2021 through BTRANS.

According to new Transfer pricing Circular serial number 3 dated 22.02.2021; the deadline for submission of the first Country by Country Report for the 2019 fiscal period and additionally the first Country by Country Report for the special fiscal period ending in January / February 2020 through BTRANS has been extended until the end of Wednesday, March 31, 2021 for the MNEs with UPEs or SPEs in Turkey. For the MNEs with UPEs or SPEs residing outside of Turkey; the 2019 fiscal period and additionally the first Country by Country Report for the special fiscal period ending in January / February, March, April and May 2020 have been extended to Wednesday, June 30, 2021.

In addition, the CBC  notification forms for 2019 fiscal period and the special fiscal period starting after 1/1/2019  which have been filed within the periods specified in the aforementioned Communiqué, in accordance with the explanations in the Internet Tax Office and the conditions on the date of issue; does not need to be corrected  due to the changes that occurred after the date (including the change of the reporting entity with the entry into force of the competent authority agreement for the change of CbC reports.

Please find below the link for the detailed information regarding the Decision.

https://www.gib.gov.tr/node/151729

Regards,