Transfer Pricing

Transfer Pricing

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  • Ercan ALPTÜRK
    Ercan ALPTÜRK    Premium Member   Group moderator
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    TAX CERTIFICATION IN FULL,TURKEY
    TAX CERTIFICATION IN FULL

    In this engagement, accounting records and tax compilations of our client are examined for the purpose of maintaining compliance with tax legislation. These examinations are carried out in accordance with the standards developed by the tax authority of Turkey, in detail and on continuous basis. At completion of these examinations, a “tax certification report” including our opinion concerning the compliance of the tax returns and financial statements attached thereon with tax legislation is submitted to the tax office of our client. SCPA(1) is held jointly responsible for tax related non-compliances occurred in the period covered by his/her report. The context of this responsibility is also stated in the relevant legislation.

    TAX CERTIFICATIONS IN TRANSACTIONS

    Tax authority of Turkey, having been empowered by relevant legislation, has identified certain tax law clauses [i.e. transactions] which provide the tax payers with some sorts of easiness or rights, and determined that tax payers who want to benefit by these clauses should submit a special “SCPA(1) certification report”. Submission of such a report is in some cases an absolute condition and in some cases an alternative condition.

    The list of such transactions and relevant application details change in time in parallel with the amendments of tax laws and with the changes in the decisions of tax authority. However, these transactions are generally related with topics such as,

    Incentives and exemptions in income taxes,
    Refunds in value added taxes,
    Deferral and cancellation or low rate application in special transaction taxes,

    In this engagement, all relevant transactions of our client are examined in accordance with the standards developed by the relevant state authority. At the end of the engagement, a special “SCPA certification report” is submitted to our client.

    OTHER CERTIFICATIONS AND EXAMINATIONS

    Some non-tax government authorities, having been empowered by relevant legislation, identify certain sensitive transactions and lay down the submission of a “SCPA(1) certification report” as a condition for the conduct of these transactions. For example, (a) Radio and TV Superior Council of Turkey asks radio and TV broadcasting companies to submit such report in relation with advertisement revenues and computation of Council share of said revenue, (b) Prime Ministry Treasury Undersecretary, as a condition of his approval of the completion of an investments which have benefited from some kind of state incentives, asks for SCPA approval of the exchange gain/loss amounts and interest amounts included in the total cost of the investment. We examine such sensitive transactions of our clients in accordance with the standards developed by relevant government authority and a special “SCPA certification report” or “SCPA approval document” is submitted to our client.

    On the other hand, some private institutions also need the services of SCPA. For example, establishment articles of some non-government organizations (associations or foundations) include clauses requiring examination of the accounts by a SCPA. Accounts of our such clients are examined in accordance with relevant standards and a “SCPA examination report” is submitted to our client.




    Footnotes:
    (1) SCPA: Sworn-in Certified Public Accountant
    • 23 Nov 2010, 12:40 am