Türkiye - Introduces AI-Based Transfer Pricing Risk Analysis

Summary

On August 12, 2026, the Turkish Tax Inspection Board (Vergi Denetim Kurulu, VDK) announced the activation of the VDK-MİHENK system for centralized risk analysis. The system uses artificial intelligence and big data analytics to evaluate financial data, including electronic documents, and identify potential risks involving transfer pricing, the arm’s length principle, and the transfer of profits between related parties through pricing.

Key Points

1. System Activation and Purpose

The VDK-MİHENK system was developed by the Tax Inspection Board and activated for use in centralized risk analysis. Its stated purpose is to strengthen the identification of potential tax risks, particularly those related to transfer pricing and the arm’s length principle.

2. Data Sources and Analytical Approach

The system evaluates financial data available to the Tax Inspection Board, including electronic documents, using artificial intelligence and big data analytics. It analyzes multiple economic transactions together to examine relationships among prices, costs, sales volumes, and other economic indicators relating to goods and services.

3. Analysis of Related-Party Transactions

The system is designed to analyze related-party transactions priced both above and below comparable benchmarks. Its analysis uses datasets comprising multiple actual economic transactions rather than relying solely on a limited number of examples or individual transactions.

4. Geographic and Economic Comparability Factors

The system incorporates different data dimensions to support comparability analysis, including geographic and economic conditions. These factors are considered in evaluating the comparability of transactions rather than determining, by themselves, whether a particular price is correct or incorrect.

5. Role of Analytical Results

The system’s analytical outputs serve as inputs to centralized tax risk analysis. A price or profitability difference identified by the system does not, by itself, constitute a final tax determination or establish tax noncompliance. The nature of the transaction, its commercial circumstances, and other factors affecting comparability are considered in the risk assessment.

Source:

Vergi Denetim Kurulu Başkanlığı, VDK-MİHENK Sistemi Devreye Alındı (August 12, 2026)

https://vdk.hmb.gov.tr/duyuru/vdk-mihenk-sistemi-devreye-alindi

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Disclaimer:

This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

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