TY  - JOUR
TT  - A STUDY ON THE REASONS WHY ADVANCE PRICE AGREEMENTS ARE NOT WIDELY USED IN TURKEY
AU  - Ertürk, Erkan
AU  - Yalçıner, Kürşat
PY  - 2017
DA  - November
DO  - 10.18092/ulikidince.315545
JF  - Uluslararası İktisadi ve İdari İncelemeler Dergisi
JO  - IJEAS
PB  - Kenan ÇELİK
WT  - DergiPark
SN  - 1307-9832
SP  - 413
EP  - 424
KW  - Transfer Fiyatlandırması
KW  - Emsallere Uygunluk
KW  - Peşin Fiyatlandırma Anlaşması
N2  - Multinationalcompanies (MNCs) have a permanent business relationship between branchesoperating in different countries, and the branches exchange goods, services andtechnology among themselves. The prices that a MNC determines for goods andservices produced by its subsidiaries in various countries are transfer prices.Transfer prices are determined to increase the profitability of the MNC as awhole. Member countries of the OECD have agreed that profit from transactionsbetween related parties should be used as a reference to profit if suchtransactions are carried out by unrelated parties, in order to preventinternational double taxation and to ensure a fair distribution of taxableprofits. Advance price agreements (APAs) can be used when the transfer pricesare determined in accordance with the arm’s length. The APA is a way ofreaching an agreement with the tax authorities to deal with the transactionsthat the MNCs carry out within themselves and to determine the price that MNCwill use in the future. The purpose of this article is to provide informationabout the APA's prominence and APA regulatory process. In addition, the reasonsfor not using APA of the MNCs, which is located in the branch in Turkey, are toreveal with the questionnaire study. This research was carried out on themanagers of the MNCs in Turkey. According to the analysis results obtained, themost important reasons for why MNCs does not want to make APAs areuncertainties related to the APA process, fear of tax audit and the very longduration of the APA process.
CR  - Alm, Maria ve Ehrstedt, Helena (May 2011) Advance pricing agreements: The concept and its implementation in Swedish tax law, Jönköping, 1-97.
CR  - Anandarajan, Asokan, Mcghee, Mitch ve Curatola, Anthony P., (September/October 2007). A Guide to International Transfer Pricing, The Journal of Corporate Accounting & Finance, 33.
CR  - Borkowski, Susan C., (1993). Advance Pricing Agreements and Other Alternatives for Multinational Corporations, International Tax Journal, 19(4), 1-11.
CR  - Borkowski, Susan C., (1996). Advance Pricing (Dis) Agreements: Differences in Tax Authority and Transnational Corporation Opinions, International Tax Journal, 22(3), 23-34.
CR  - Borkowski, Susan C. and Gaffney, Mary Anne (2014). Proactive Transfer Pricing Risk Management in PATA Countries, Journal of International Accounting Research: Fall, Vol. 13, No. 2, 25-55.
CR  - Canale, David J. and Wrappe, Steven C. (2008). Advance Pricing Agreements - A Strategic Tool in Global Transfer Pricing Management, The Tax Execuive, 193-203.
History of the US APA program, June 2013, pwc.
CR  - IRS, Announcement And Report Concerning Advance Pricing Agreements, March 30, 2015.
CR  - Markham, Michelle (2012). Advance pricing agreements: Past, present and future, Advance pricing agreements: Past, present and future, Kluwer Law International BV, 1-410.
CR  - Nehoray, Mark ve Ishii, Reiko, (2009).  How APAs fit into today's regulatory landscape, International Tax Review, 09587594, May 2009, Cilt 20, Sayı 4, 72-74.
CR  - OECD Transfer Pricing Methods, July 2010.
CR  - OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010.
CR  - Oluwaseun, Olanrewaju Avoseh (2014). An Empirical Evaluation Of The Advance Pricing Agreement Process In The UK, Business School College Of Social Sciences, University Of Glasgow, 1-242.
CR  - Ring, Diane M. (2000). On the Frontier of Procedural Innovation: Advance Pricing Agreements and the Struggle to Allocate Income for Cross Border Taxation, Michigan Journal of International Law 21, no.2, 143-234.
CR  - Rutges, Dave, Sporken, Eduard, Van Stappen, Dirk, Luquet, Pascal, Hickman, Andrew (2006). EU cooperation brings out benefits of advance pricing agreements, International Tax Review, 09587594, Cilt 17, Sayı 6, 62-64.
CR  - Snowdon, Catherine (2010). OECD Has Work To Do On APA Guidelines, International Tax Review, 09587594, Cilt 21, Sayı 7, 15-17.
CR  - Sumay, Serdar, Peşin Fiyat. Anlaşmaları, www.dünya.com, 31 Ocak 2015.
CR  - Whitford, Andrew B. (2011). The Reduction Of Regulatory Uncertainty: Evidence From Transfer Pricing Policy, Saint Louis University Law Journal (Vol. 55:269 2010-2011), 269-306.
CR  - Wittendorff, Jens (2010). Transfer Pricing and the Arm’s Length Principle in International Tax Law, Kluwer Law International, 19. www.ey.com.
CR  - Yalçıner, Kürşat (2008).Uluslararası Finansman, Gazi Büro Kitapevi, 345.
CR  - Zhang, James (2012). Tax Planning for Multinational Enterprises: A Proposed Course for Global Business Education, on the SSRN database, 1-55.
UR  - https://doi.org/10.18092/ulikidince.315545
L1  - https://dergipark.org.tr/en/download/article-file/346172
ER  -