Türkiye announced not to apply Amount B

Turkish Revenue Administration has announced that Türkiye will not adopt Amount B which is a part of Two-Pillar Approach developed by the Inclusive Framework within the scope of the OECD (Organization for Economic Co-operation and Development)/G20 BEPS (Inclusive Framework) Project. As known, Amount B Report is included in the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”. According to the report, Amount B is to be applied to the accounting periods starting on or after January 1, 2025 and is an optional application depending on the choice of the countries. Countries may choose to apply Amount B to the transactions of distributors, sales agents and commissionaires operating in their jurisdictions to simplify and streamline the application of transfer pricing policies and to reduce the compliance burden of MNEs. On the other hand, Türkiye has announced on 7 March that Amount B will not be applied in Türkiye. Thus, for MNEs operating in Türkiye, it is crucial to note that Amount B is not an option and OECD approved Transfer Pricing methods will be continued to be applied and a Benchmark Analysis is required. For Turkish MNEs operating in foreign countries, the status of Amount B in respective jurisdictions will be key for applying Amount B to their eligible operations.  Please kindly see the said announcement.

Sütun 1-Tutar B Türkiye’de Uygulanmayacaktır | Gelir İdaresi Başkanlığı