TAX NEWS
NO: 2021/8
Subject: Possibility To Be Provided With an Extension for Submission of 2019 Country-by-Country Reports for Those Entities Whose Ultimate Parent Entity or Surrogate Parent Entity is resident in the U.S.A.
According to an announcement made by the Turkish Revenue Administration (TRA) on 28 June 2021 through the electronic platform of the TRA Information Transfer System (“BTRANS”) ; considering the fact that the “Bilateral Competent Authority Agreement between Turkey and the U.S.A. on the Exchange of Country-by Country Reports“ is still under negotiation; those entities in Turkey whose Ultimate Parent Entity or Surrogate Parent Entity is resident in the U.S.A. and, who are obliged to submit the first Country-by-Country Report (CbCR) for 2019 or for the fiscal period that starts after 1 January 2019 to the TRA by 30 June 2021 through BTRANS, will be able to be provided with an additional time to submit their first CbCRs, provided that they apply, in writing through a petition, to the Transfer Pricing Unit of the Department of EU and Foreign Affairs in the TRA within 15 days from the date of 28 June 2021.
When requesting additional time to submit the 2019 CbCR, it will be sufficient just to request an additional time for extension, without specifying any period or date. The TRA will accordingly reply to the individual applications to provide the necessary extension.
To give examples; Turkish companies whose ultimate parent entities are resident in the U.S.A. and, who are obliged to submit the first CbCR normally by 30 June 2021, for the year 2019 or for the fiscal period ending on 30 June 2020, will be able to apply through a petition in writing to the Transfer Pricing Unit of the Department of EU and Foreign Affairs in the TRA within 15 days from 28 June 2021 by requesting additional time for submission of the first CbCR for 2019 or for the fiscal period ending on 30 June 2020.
The announcement of the TRA in Turkish is also attached to our news bulletin.
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