All posts by Gokhan Yurdakul

<p>Transfer pricing (TP) adjustments, retroactive price revisions, and debit note flows between related parties represent one of the most critical and frequently challenged areas in Turkish customs practice. While these adjustments are primarily driven by corporate tax compliance requirements, their direct and often underestimated impact on customs valuation creates a structural compliance risk for importers operating in Türkiye. In practice, many companies manage transfer pricing correctly from a tax perspective but fail to reflect these adjustments in customs declarations, resulting in a disconnect between financial records and customs value.</p><p>This gap is no longer tolerated in the current enforcement environment. Customs authorities have significantly increased their focus on post-clearance audits, particularly in areas where accounting data can be cross-checked against customs declarations. Transfer pricing adjustments, by their nature, leave a clear financial trace. As a result, what may appear to be a routine accounting correction can quickly evolve into a customs valuation issue with retroactive duty exposure, VAT reassessment, and substantial administrative penalties.</p>

<p>As of 2026, the changes introduced in <strong>Türkiye’s TAREKS (Risk-Based Foreign Trade Control System)</strong> do not merely constitute a procedural update; they represent a structural transformation that fundamentally reshapes the approach to import controls under <strong>Turkish customs and product safety legislation</strong>. In particular, the effective abandonment of the traditional concept of “no-scope declaration” has created a new inspection reality for companies importing goods into Türkiye.</p><p>Under the new Turkish practice, declaring that a product is outside the scope of a specific product safety regulation is no longer an exception that accelerates customs clearance. Instead, such a declaration now serves as the <strong>starting point of technical and regulatory inspection</strong> carried out through TAREKS.</p><p>Within this framework, TAREKS has evolved from a system that merely filters products subject to control into a <strong>central inspection mechanism</strong> under Turkish law, requiring even allegedly out-of-scope products to be assessed from <strong>technical, legal, and functional perspectives</strong>. The most visible consequence of this transformation is the significantly increased importance of <strong>HS Code (GTİP) analysis</strong> and <strong>technical file quality</strong> in imports to Türkiye.</p>

One of the most technically demanding and dispute-prone areas in customs valuation concerns buyer-supplied goods and services, including engineering, development, design and technical services, as regulated under Article 27(1)(b) of the Turkish Customs Law. These elements, commonly referred to as assists, rarely remain a simple valuation adjustment in practice. Particularly in transactions between related parties, assists often evolve into a complex and multi-layered compliance risk.

The concept of customs value is arguably one of the most debated and disputed topics in customs legislation. The main reason is that the customs value of imported goods must be determined based on the specific conditions of the commercial transaction.

Let’s illustrate this with a real-world example. An importer purchases plastic components from an overseas manufacturer. The invoice merely states “plastic parts,” and the HS Code appears correct.

Geopolitical disruptions, the reconfiguration of supply chains, and the rise of e-commerce have transformed customs processes from a task of simply filling out declarations into a strategic domain where corporate risk, cost, and speed must be managed in balance. In this transformation, competitive advantage depends not only on the maturity of data + process + compliance, but also on timely and accurate access to local expertise. While fragmented data and ad-hoc access to experts create delays, penalties, and reputational risk, integrated data and traceable processes lower total cost and enable predictable delivery.

In recent years, Türkiye has become not only a regional but also a global hub for trade. Positioned strategically between Europe, the Middle East, and Central Asia, the country offers strong production capacity, a young and skilled workforce, an advanced logistics network, and a growing domestic market — all of which make it an attractive destination for international companies. Yet, this very dynamism that creates opportunity also brings complexity and risk.