Benchmarking & Comparability Analysis

The single biggest driver of whether a transfer pricing position survives assessment. We build defensible, multi-year comparability searches using Indian and global databases.

Overview

Method selection first, comparables second

Every benchmarking exercise starts with choosing the "most appropriate method" based on the transaction's nature and available data — not defaulting to whichever method is administratively easiest. Only then do we build the comparable set.

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Who this applies to

Any entity needing to establish or defend an arm's-length price, margin, or royalty rate for a related-party transaction.

What We Cover

All six prescribed methods

CUP

Comparable Uncontrolled Price — for goods, royalties and financial transactions.

RPM / CPM

Resale Price and Cost Plus Methods for distribution and manufacturing.

TNMM

Transactional Net Margin Method — the most widely applied method in India.

PSM & Other Method

Profit Split for integrated transactions; Other Method for unique/intangible cases.

Our Process

A rigorous, documented search

Step 1

Data Availability Test

Assess which methods have reliable comparable data for your transaction.

Step 2

Search Strategy

Define screening criteria and document the rejection matrix.

Step 3

Comparable Selection

Multi-year search across Prowess, Capitaline and global databases.

Step 4

Range & Adjustment

Compute the arm's-length range and apply working capital/risk adjustments.

Why Work With Us

Comparables chosen for defensibility, not convenience

Documented Search Strategy

Every inclusion and rejection is recorded and justified.

Sector Specialisation

Industry-specific comparable sets, not generic templates.

Multi-Database Access

Indian and international financial databases for every method.

FAQs

Common questions

How many comparable years of data are used? +

Indian TP rules generally require the current year's data, with the option to use up to two prior years where current-year data isn't available at the time of documentation, subject to prescribed conditions.

Can I use overseas comparables for benchmarking? +

Indian comparables are generally preferred and more defensible, but overseas comparables may be used where local data is genuinely unavailable and comparability can be established.

Need a defensible benchmarking study?

Get a free assessment of your comparable set.