Country-By-Country Reporting Submission in Turkey Has Been Postponed to 26 February 2021

Turkish Revenue Administration published a circular “Circular on Disguised Profit Distribution Through Transfer Pricing/2” on 18 December which includes announcement of extension of Country-by-Country Reporting (CbCR) filing deadlines in order to satisfy taxpayers’ demands for postponement of this new transfer pricing filing obligation deadline.

According to the circular, deadline for;

• the first CbCR filing for 2019, and
• the first CbCR filing through BTRANS system for the special accounting period ending in January 2020,

which was determined as 31 January 2021 previously, has been postponed to 26 February 2021 in line with Article 6 of Presidential Decree no. 2151.

CbCR Requirements in Turkey actually were introduced with Presidential Decree No. 2151, which was published in the Official Gazette dated 25.02.2020.  Our detailed explanations on CbCR requirements in Turkey were included in the Guide we prepared in the form of a Question and Answer.

On the other hand, CbCR filing for special accounting period ending February 2020 and beyond must be submitted electronically until the end of the following 12 months after the end of this period.

Reporting companies in Turkey must complete their application to BTRANS system in order to be authorized to transmit CbCR filing before the first submission date. Companies are required to apply to Turkish Revenue Administration with a petition signed in ink to request user code and password which is necessary for submission through BTRANS system.  

However, multinational Turkish enterprises will submit their CbC reports in the other countries where CbCR filing is mandatory, and also in Turkey until 26 February 2021 unless the application of multilateral competent authority agreement on the exchange of CbC reports will be initiated until that time.

We recommend multinational enterprises in Turkey to prepare their CbC reports in the additional time of nearly two months if they haven’t yet. Otherwise, companies will face serious penalties in case of inconsistency with law. Companies which will submit their mandatory CbC reports in other countries might be required to submit their CbC reports in Turkey once again if the application of multilateral exchange of CbC reports will not be initiated until 26 February 2021.

Kind Regards,