Amount B Will Not Be Applied in Turkey

Amount B Will Not Be Applied in Turkey

In a recent development related to international tax reforms, Turkey has announced that Amount B will not be implemented for entities operating within the country.

Background on Pillar One and Amount B

The initiative stems from the work under the Inclusive Framework developed by the OECD (Organisation for Economic Co-operation and Development)/G20 BEPS (Base Erosion and Profit Shifting) Project. As part of the two-pillar approach, the first pillar—referred to as “Pillar One”—includes provisions for Amount B. The initial phase of studies concerning Amount B culminated with a report published on the OECD’s website on February 19, 2024. This report is also incorporated into the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.”

Key Details on Amount B

According to the report, Amount B has been designed for financial periods beginning on or after January 1, 2025. Its application is optional and subject to the choice of individual countries. In practical terms, nations have the discretion to apply Amount B for relevant transactions carried out by distributors, sales agents, and commission agents operating within their borders, for periods starting from January 1, 2025, onward.

A consolidated document on this subject was later published on the OECD website on February 24, 2025.

The Turkish Position

In conclusion, for this stage of implementation, Turkey has decided that Amount B will not be applied to the transactions of distributors, sales agents, and commission agents operating domestically. This decision underscores the country’s current stance on the evolving international tax framework.

Turkey respectfully informs the public of this update.

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