Benchmark · OECD Chapter III

Transfer pricing benchmark analysis: comparables and the arm's length range

A documented search for comparable independent companies and transactions. Without a benchmark, your study does not defend the arm's length range.

We reply on the next working day. We name the fee in writing, in our reply to your inquiry. Scope and timing are confirmed in writing before work starts.

Updated Sources checked

  • Benchmark analysisfrom €2,000
  • RangeQ1-Q34
  • FrameworkOECD Chapter III4

In short

  • A benchmark analysis compares profitability or prices with comparable independent companies from commercial databases.

  • The result is a range of market values; where comparability is not perfect, the OECD Guidelines allow the interquartile range, and a result within the range supports the conclusion that the price is at arm's length.

  • The OECD Guidelines state that tax administrations may allow the database search to be renewed every three years, with the financial data of the comparable companies updated every year.

01Service

What a benchmark analysis is and why it matters

A benchmark analysis is a systematic search for comparable independent companies and transactions. The result is a range of market values for the key indicator, for example operating margin, mark-up on total costs or the Berry ratio. Where comparability is not perfect, the OECD Guidelines allow statistical tools such as the interquartile range (Q1-Q3).

02Service

Which databases are used

In practice, benchmarks use commercial databases, for example:

  • Orbis (Moody's, formerly Bureau van Dijk): a global database of company financial data.

  • TP Catalyst: a database specialised in transfer pricing, with ready-made search procedures.

  • RoyaltyStat / ktMINE: for royalty rate benchmarks.

  • Loan Connector / DealScan: for intercompany loan and interest rate benchmarks.

IIIProcess and timing

Our benchmark process

A benchmark analysis is not a list pulled from the internet. It is a documented, defensible process.

  1. 01Defining the tested party and the controlled transaction

  2. 02Choosing the PLI (Profit Level Indicator)

  3. 03Database search strategy

    Geography, activity by NACE code, financial filters.

  4. 04Quantitative screening

    Working capital, indebtedness, years of data, profitability.

  5. 05Qualitative screening

    With a rejected companies log (why we rejected each one).

  6. 06Calculating the range and the median

    The interquartile range (Q1-Q3) where needed.

  7. 07Comparison with the tested party's result and a recommendation

IVMethodology

If the tested party's result is within the range, this supports the conclusion that the price is at arm's length. If it is not, an adjustment or further analysis of the reasons is needed.

What a benchmark analysis is and why it matters

VIFee

Standalone benchmark analysis

A benchmark is also part of the full study + benchmark package (€2,500 – 4,500).

from €2,000

Standalone benchmark analysis · Timing is confirmed in writing before work starts, with the scope.

  • Intercompany interest rate benchmarkfrom €1,800

Scope, timing and fee are confirmed in writing before work starts. What is not included is listed in the written offer.

VIISources and legal framework

Primary sources for this page

Content prepared and checked by the Schule d.o.o. Podgorica team. The sources are in Montenegrin; this page is general information, not advice for a specific case.

Updated Sources checked

This page in Montenegrin

VIIIQuestions

Questions clients ask about this topic

How long is a benchmark analysis valid?

The OECD Guidelines (para. 5.38) state that tax administrations may allow the database search to be renewed every three years, if the operating conditions have not changed, with the financial data of the comparable companies updated every year. The Montenegrin rules we checked do not regulate this separately.

What if our result falls below Q1 of the benchmark range?

You have three options: adjust the prices, explain why your functions and risks fall outside the range, or make a structural change (for example a different allocation of functions). We guide you through the decision.

Inquiry

Tell us about your related parties and transactions

We reply on the next working day. Scope, timing and fee are confirmed in writing before work starts.

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IXNext step

Describe your related parties and transactions: we reply on the next working day

We reply on the next working day. We name the fee in writing, in our reply to your inquiry. Scope and timing are confirmed in writing before work starts.