Benchmark analyses are an important instrument for proving the arm's length nature of transfer prices. It must be ensured that, for reasons of consistency, globally uniform criteria are applied in a group of companies for the selection of comparable companies or transactions and that a process that is transparent and comprehensible for the tax authorities is used as a basis.
KPMG prepares analyses tailored to your needs using your internal data as well as external data and information sources, which are usually subject to a fee. Our services include the following:
- Global, regional and local database studies (e.g. AMADEUS, Compustat, Orbis) to determine ranges of appropriate profitability ratios of comparable companies, including the performance of adjustment calculations (e.g. adjustment for size degression effects, working capital adjustments).
- International database studies (e.g. ktMINE, RoyaltyStat) to determine ranges for licence or commission rates on the basis of conditions contractually agreed between third parties and/or information on purchase price allocations
- Determination of ranges for arm's length loan interest rates, guarantee commissions, leasing and factoring fees as well as remuneration for other intra-group financing transactions based on rating analyses (e.g. by means of Moody's RiskCalc or derivation of existing group ratings), database-supported analyses of comparable transactions between third parties (e.g. Thomson Reuters, DealScan / LoanConnector) or adjustment calculations based on internal price comparisons, among others
- Preparation of econometric analyses, e.g. to prove the statistical robustness of database studies and to prepare internal company data as a basis for an arm's length analysis.
Michael Freudenberg
Partner, Tax - Head of Global Transfer Pricing Services
KPMG AG Wirtschaftsprüfungsgesellschaft
+49 211 475-7584 Michael
Freudenberg
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