01.06.2022/39
On the Submission of the Notification Form for Country-by-Country Reporting for Multinational Enterprises
Until the end of June, the Notification Form for Country Based Reporting, which is included in the Communiqué Serial No. 4 on the Amendment to the General Communiqué on Disguised Profit Distribution through Transfer Pricing No. 1 dated 01.09.2020 and numbered 31231, will be filled in accordance with the content in Annex (5) of the Communiqué and the explanations in the Internet Tax Office and will be submitted electronically via the Internet Tax Office.
The following are the important points that multinational business groups should pay attention to when completing the notification form:
- Since the notification form is a form containing information such as the ultimate parent entity, proxy entity, which entity will report on behalf of the group, accounting period, etc., the requested information must be submitted to the Administration with a new notification form every year via the Internet Tax Office.
- Until June 30, 2022, the notification form is to be completed by all covered corporate taxpayers for the accounting period 1/1/2021 – 31/12/2021 and the special accounting period ending in 2021. Scope means that the consolidated group income for the accounting period preceding the reported accounting period, i.e. the accounting period 1/1/2021 – 31/12/2021 and the special accounting period ending in 2021, is above the threshold of EUR 750 million or the threshold set in local currency by the administration of the country where the ultimate parent/subsidiary is located.
- In the section of the notification form titled “Ultimate Parent Enterprise/Agent Enterprise Information”, the ultimate parent enterprise column should be filled in completely by all enterprises submitting a notification form. The proxy enterprise column should be filled in if there is an enterprise appointed by the ultimate parent enterprise to report on behalf of the ultimate parent enterprise, and the proxy enterprise column should be left blank if the ultimate parent enterprise is located in Turkey.
- The notification form will also be completed by the entity (one of the entities if there is more than one entity) located in Turkey of a group of multinational enterprises whose ultimate parent/agent entity is not located in Turkey.
In cases where the “Competent Authority Agreement on the Exchange of Country-Based Reports” is activated or bilateral agreements on the exchange of country-based reports are in force between Turkey and the country where the ultimate parent enterprise/surrogate enterprise is located, the notification form will be submitted by the enterprises located in Turkey of the multinational enterprise group whose ultimate parent enterprise/surrogate enterprise is not located in Turkey, regardless of whether these agreements are in force/activated or not. Whether the agreements in question are in force/activated or not will be specified when answering the questions in the section titled “Ultimate Parent Enterprise/Surrogate Enterprise Information” in the content of the notification form.
- If it is determined that there is an error or deficiency in the notification form submitted after the notification form is submitted until June 30, 2022, the correction can be made by sending the notification form until the end of the month following the end of the submission period, that is, until July 31, 2022. However, if the correction notification is submitted after the deadline, penal action will be applied in accordance with the provisions of the Tax Procedure Law.
You can access the relevant Revenue Administration announcement here.
Sincerely,
BİLGENER
