What is included in the fee for tp benchmarking study?
A documented search: screening criteria, quantitative and qualitative filters, a manual rejection log with reasons, and the resulting range with the tested party's position in it.
What would make tp benchmarking study cost more than the standard tier?
How defensible the comparables have to be. A study intended for a filing and a study intended to survive an audit are different pieces of work.
Is the fee really fixed?
Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.
How often does a benchmarking study need to be refreshed?
It depends on whether the underlying transaction and market conditions have materially changed, but a study is generally reviewed periodically rather than relied on indefinitely, since comparable-company data and the transaction itself can both drift from what an older study assumed.
Can one benchmarking study support related-party transactions in more than one country?
Sometimes, where the underlying transaction and the comparable set are genuinely applicable across the jurisdictions involved, but each country's own documentation requirements need to be checked, since a study built for one country's rules does not automatically satisfy another's.
What makes a benchmarking study defensible if it is ever challenged?
A clear functional analysis matching the tested party's actual role, a comparable set built from genuinely similar transactions, and a documented rationale for the method chosen are what make a study defensible — a study that skips the functional analysis and jumps straight to a comparable set is the kind that does not hold up under review.
Does a benchmarking study need updated financial data every year even if the transaction itself hasn't changed?
Generally yes, since the arm's length range a study supports is built from comparable companies' financial results for the period in question, and using stale financial data even for an unchanged transaction can understate or overstate the current arm's length range.
What is an advance pricing arrangement?
An agreement with a tax authority, in advance, on how a category of intercompany transactions will be priced for a set number of years. Unilateral arrangements bind one country; bilateral or multilateral ones bind both sides of the transaction and are what actually removes the risk of an adjustment in one country without relief in the other. They take real time and full disclosure, so they suit large recurring flows rather than one-off transactions. See our transfer pricing work.
What is OECD Pillar One?
The part of the international agreement that reallocates a share of taxing rights over the very largest and most profitable groups to the jurisdictions where their customers and users are, regardless of physical presence — plus a simplified approach to routine marketing and distribution returns. It is aimed at the digitalised economy problem that physical-presence rules could not reach, and its implementation is still moving, which is why we read the current instrument rather than the original blueprint. See BEPS and Pillar Two.