Turkey (Türkiye): Country-by-country reporting, automatic exchanges under CbC MCAA

Turkey: Country-by-country reporting

Turkey has activated its relationship with 38 countries regarding the automatic exchange of country-by-country (CbC) reports within the framework of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA).



The CbC MCAA was approved and published in Turkey’s official gazette (1 October 2020); thereby, Turkey is considered a signatory of the CbC MCAA as of 30 December 2019.

Accordingly, the automatic exchange of CbC reports will be performed between Competent Authorities of countries that are signatory parties to the CbC MCAA. With the signing and completion of the necessary activation procedures regarding the CbC MCAA, Turkish resident entities that are part of foreign-headquartered multinational enterprises (MNEs) are not required to submit the CbC report to the Turkish tax administration. Rather, MNEs that have their ultimate parent entity (UPE) in Turkey will submit their CbC reports to Turkey and they will not assign any surrogate entities in other jurisdictions covered under CbC MCAA.

Under the CbC MCAA process, tax jurisdictions aim to increase tax transparency in order to assess how multinational businesses structure their activities and to assess high-level transfer pricing risks and other base erosion and profit shifting (BEPS) risks as well as economic and statistical analysis.

While the exchange of information for tax purposes, including automatic exchange of information, will take place between Competent Authorities, bilateral or multilateral exchanges of information may also be mutually agreed.

In addition, there is a CbC reporting notification obligation, requiring taxpayers to submit these CbC notifications to tax authorities by the end of June of each year.

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Turkey:

Başak Diclehan | bdiclehan@kpmg.com

© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us