The JTPF experts' forum has released the final version of the report on the application of the benchmarking approach for transfer pricing in the EU Member States "REPORT ON THE USE OF COMPARABLES IN THE EU."

The document focuses on the problem of finding comparative data. It contains 8 detailed recommendations, which include:

  • Process diagrams and documentation of the course of searching for comparison data (formulation of analysis assumptions, quantitative analysis, qualitative analysis);
  • Principles of treatment of comparative data acquired from internal and external transactions,
  • Information sources in EU,
  • Selection of comparative data by the analysis of the identified value range and multi-term data,
  • The problem of correcting comparative data including in the context of the geographical factor.

The document is essentially based on TPG records but allows for some areas to be refined. Much emphasis is placed on documenting the search for comparative data and justification for all necessary steps in the process, and thus on transparency from evidential needs as well as on the consistency of the procedure used and the maximization of the objective approach.