Transfer Pricing Benchmarking
Transfer pricing benchmarking grounded in real data.
Database-driven comparables searches that establish an arm's length range for every intercompany transaction: services, distribution, IP licensing, and financing. Documented, reproducible, and refreshed every year.
Trusted by global businesses
An unsupported markup is the
weakest position in a TP inquiry.
Every intercompany price you charge is a claim that an independent party would have agreed to the same terms. Benchmarking is the evidence behind that claim. Without it, the number is just an assertion, and the auditor knows it.
The round number that 'felt right'
Someone picked a markup years ago because it sounded reasonable. There is no study behind it, nobody remembers the rationale, and it has been copied forward into every return since.
The search can't be reproduced
If the methodology isn't documented, an auditor can't verify it, and a study that can't be re-run carries little evidentiary weight. The screening logic matters as much as the result.
One range stretched across everything
Services, distribution, IP licensing, and intercompany financing are different transactions with different comparables. A single markup applied to all of them is a finding waiting to be written.
What you get
What the service includes.
Tested party and method selection
We select the tested party and the transfer pricing method per transaction type against OECD guidance, and document the reasoning an auditor will test first.
Database-driven comparable search
Comparables screened from recognized commercial databases, with every quantitative and qualitative screen recorded, including what was rejected and why.
Arm's length range, quantified
Interquartile analysis with median and tested-party positioning, established per transaction type and geography. A range you can point to, not a number you defend from memory.
Every transaction type covered
Separate analyses for intercompany services, distribution, IP licensing, and financing. Each flow gets its own comparables set and its own range.
Documented, reproducible methodology
The full search strategy is written down: databases, screens, and selection logic. Re-run the study and you land on the same set. That is what auditable means.
Annual refresh, included
Benchmarking is refreshed every year as market conditions change, so the range in your documentation never lags the market you operate in.
How it works
From transaction map
to defensible range.
The same defined workflow whether it's your first study or a refresh of one that has gone stale.
Step 01
Characterize the transaction
We map the intercompany flow, build the functional profile of each side, and select the tested party and method that fit the facts.
Step 02
Screen the databases
Comparables are pulled from recognized commercial databases and filtered through documented quantitative and qualitative screens.
Step 03
Establish the range
Interquartile analysis sets the arm's length range, with the median and your tested party's position quantified per transaction type and geography.
Step 04
Refresh annually
The study is refreshed each year as part of the engagement, and the updated range flows straight into your documentation package.
A snapshot,
or a system.
Advisors deliver a benchmarking study as a one-off project at advisory rates, then quote again when it goes stale. Commenda systematizes the recurring work, so the range stays current without a new engagement every year.
The one-off benchmarking study
A snapshot, billed again next year.
- Commissioned once, then forgotten
- Manual searches at advisory rates
- Methodology lives in one analyst's head
- Range goes stale as the market moves
- Disconnected from the documentation that cites it
- Deep jurisdiction expertise (retain for complex one-offs)
Commenda benchmarking
A maintained analysis, not a snapshot.
- Search methodology documented and reproducible
- Interquartile range with tested-party positioning
- Separate analysis per transaction type
- Annual refresh built into the engagement
- Feeds directly into your Master File and Local Files
- TP experts behind every study
Where it fits
The range is the foundation.
The documentation sits on it.
Benchmarking sets the arm's length range, your intercompany agreements apply it, and the documentation package proves it. Commenda runs all three on one platform, so the number in your agreements, your books, and your Local Files is the same number.
Common questions
Recognized commercial databases, the same class of sources tax authorities and advisory firms rely on. What matters more than the database name is the methodology: every search strategy, screen, and rejection decision is documented, so the study is reproducible and an auditor can re-run the logic and land on the same set.
The tested party is normally the entity with the simpler functional profile, because its results can be reliably compared against independent companies. The method follows the transaction: cost-plus or TNMM for intercompany services, resale-price or operating-margin analysis for distribution, and profit-based or comparable-licence approaches for IP. We select both per transaction type against OECD guidance and document why, since the 'why' is what gets tested at audit.
The markup should reflect what an independent provider doing the same functions, with the same risks, would charge. That is established through benchmarking against comparable companies in recognized databases, with the tested party positioned inside the resulting interquartile range. A round number that 'feels right' is the weakest position in any TP inquiry, however reasonable it looks. A data-backed range with documented methodology is what holds.
Annually. Market conditions move, comparables drop in and out of the set, and most jurisdictions expect the financial data behind your range to be current when you file. Commenda builds the annual refresh into the engagement, so the range in your documentation always reflects the market you're actually operating in.
Yes. Intercompany financing needs an arm's-length interest rate the same way a services flow needs an arm's-length markup, supported by comparables analysis that accounts for currency, term, and the borrower's credit profile. We cover services, distribution, IP licensing, and financing as distinct analyses, because one range stretched across four transaction types satisfies nobody.
The documentation rests on the benchmarking. A Local File that cites a stale or unsupported range is the first thing an auditor attacks, and the rest of the package falls with it. If your documentation is current but the underlying study is years old, refreshing the benchmarking is usually the single highest-leverage fix.
Put data behind
every intercompany price.
Book a 30-minute call. We'll look at your intercompany transactions, tell you which flows need their own analysis, and show you what the finished study looks like.
