The Turkish Revenue Administration (TRA) has issued specific regulations and guidelines regarding CbC reporting to ensure compliance and facilitate the implementation of the international standards. Here are some key aspects of the regulations and guidelines provided by the TRA:

1. Regulation on Country-by-Country Reporting: The Regulation on Country-by-Country Reporting, issued under Law No. 6728 on the Prevention of the Laundering of Crime Revenues, serves as the primary legal framework for CbC reporting in Turkey. It outlines the requirements and obligations of MNEs operating in Turkey regarding the preparation, submission, and exchange of CbC reports.
2. Reporting Threshold: According to the current regulations, CbC reporting in Turkey is applicable to MNE groups whose consolidated revenue exceeds TRY 3.5 billion (approximately USD 500 million) in the preceding fiscal year. However, it is crucial to stay updated with any changes in the threshold, as it may be subject to revision.
3. Ultimate Parent Entity (UPE) and Surrogate Parent Entity (SPE): The regulations clarify that the UPE, which is a Turkish tax resident, has the primary responsibility for preparing and filing the CbC report with the TRA. If the UPE is not located in Turkey, but there is an SPE in Turkey, the SPE assumes the responsibility for filing the CbC report.
4. CbC Reporting Template: The TRA adopts the standard template provided by the Organization for Economic Cooperation and Development (OECD) for the preparation of CbC reports. The template includes various information such as the revenue, profit, taxes paid and accrued, tangible assets, employees, and details of constituent entities in different jurisdictions.
5. Filing Deadline: The CbC report must be submitted to the TRA within 12 months following the end of the reporting fiscal year. It is crucial for MNEs to meet this deadline to ensure compliance and avoid penalties.
6. Notification Requirements: In addition to the CbC report, Turkish constituent entities of the MNE group are required to submit a notification to the TRA, indicating the identity and tax residency of the UPE or the SPE. This notification must be filed by the last day of the fiscal year.
7. Exchange of Information: The TRA participates in the automatic exchange of information (AEOI) mechanism established by the OECD. The CbC reports filed with the TRA are exchanged with tax authorities of other jurisdictions, promoting transparency and cooperation in combating tax avoidance.
8. Penalties for Non-Compliance: Non-compliance with CbC reporting obligations can result in penalties and administrative measures. The TRA has the authority to impose financial sanctions on MNEs that fail to meet their reporting requirements or provide inaccurate or incomplete information.
9. Confidentiality and Data Protection: The TRA maintains strict confidentiality of the CbC reports and related information, adhering to both domestic regulations and international standards. This ensures the protection of sensitive business data and promotes trust between the tax authorities and MNEs.

MNEs operating in Turkey should refer to the official guidelines and updates provided by the TRA to ensure accurate compliance with CbC reporting requirements. It is advisable to seek professional assistance to navigate the complexities of the regulations and ensure timely and accurate reporting.