Benchmarking in Transfer Pricing - Building Robust Comparability & Compliance

Introduction

As comparability analysis becomes increasingly scrutinised by tax authorities worldwide, understanding how to design, execute and document reliable benchmarks is essential.

Delivered by expert speaker Rafaela Oplopoiou-Chapman, this live and interactive sessionprovides a practical and comprehensive exploration of benchmarking within the transfer pricing framework.

Ideal for tax professionals, legal advisors, compliance teams and finance managers, this session delivers actionable insights and strategies to strengthen benchmarking quality and defendability across all types of intercompany transactions.

What You Will Learn

This live and interactive session will cover the following:

• Overview of benchmarking in transfer pricing
• Definition and purpose of benchmarking
• Role of comparability analysis in the arm’s length principle
• Regulatory framework (OECD guidelines and local regulations)
• Benchmarking workflow and key concepts
• Identifying the tested transaction
• Selecting the most appropriate transfer pricing method
• Determining the tested party
• Understanding comparability factors (functions, assets, risks, contractual terms, economic circumstances)
• Data sources and comparable selection
• Internal vs. external comparables
• Database search strategies
• Screening criteria and rejection filters
• Handling limited comparability in specialised industries
• Performing the benchmarking analysis
• Developing a search strategy
• Applying quantitative screens
• Conducting qualitative reviews
• Adjusting for differences (working capital, risk, asset intensity)
• Constructing arm’s length ranges (full range, interquartile range)
• Benchmarking for intangibles
• Royalty rate benchmarking
• Licensing comparables
• Challenges with unique or hard to value intangibles
• Impact of BEPS on benchmarking
• DEMPE alignment
• Substance based comparability
• Strengthened documentation requirements
• Documentation and compliance
• Presenting benchmarking results in Local File and Master File
• Explaining methodology, assumptions, and limitations
• Audit ready documentation practices
• Common pitfalls and how to avoid them
• Practical case studies and exercises

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.