This article considers royalty payments in Turkey from a tax and transfer pricing perspective. The focus is on both domestic and international implementations. The article evaluates taxation regime of royalties in Turkey, and royalty payments are discussed by taking into consideration certain Double Taxation Agreements executed among Turkey and its treaty partners.
It is also pointed out in the article how royalty payments to non-resident taxpayers are considered within the context of intangible rights in Turkish tax legislation and Double Taxation Agreements.
A considerable part of the article is reserved to explain details of current transfer pricing rules applicable for royalties paid in Turkey or to abroad, and it analyses the application of transfer pricing legislation for royalty payments by practical examples.Intertax