Transfer Fiyatlandırması Yoluyla Örtülü Kazanç Dağıtımında İlişkili Kişi Kavramının 6728 Sayılı Kanun Kapsamında Değerlendirilmesi
The Evaluation of Consept of Related Part At Distribution of Concealed Revenue Via Tranfer Pricing Within the Content of 6728 Numbered Law

Summary/Abstract: Some changes have been made to the Law Amending Changes in Some Laws for the Improvement of the Investment Enviroment which has numbered 6728, with article 59 of the Law, which has serial numbers one published in official journal dated August 9th, 2016 and numbered 29796 ,“distribution of concealed revenue via transfer pricing” titled 13th article of5520 numbered Corporation Tax Law. In this study, first exiting legal regulations on “related part” which is on of the factors of distribution of concealed revenue via transfer pricing presented, and then deficient aspects of this concept, which have been studies and criticized in academic literature, have been discussed after the changes that came with 6728numbered Law. It’s believed that it’s a good regulation that the condition being set with the changes of 6728 numbered Law on identifying the related part share at least 10% partnership, having the right to vote or receive dividend.

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