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Benchmarking study

Benchmarking study

Preparation of benchmarking studies aimed at verifying prices and margins in transactions between related parties.

Verifying the arm’s length nature of prices in transactions between related parties.

We offer assistance in preparing, updating and evaluating economic (comparability, benchmarking) studies, aimed at verifying prices and margins set in controlled transactions by benchmarking the arrangements in such transactions against comparable transactions concluded by independent entities.

Benchmarking study – supplementary protection for the taxpayer

Benchmarking studies are an important tool for setting, evaluating and justifying intercompany transactional arrangements. KPMG provides support in preparing such studies which – alongside the tax documentation – help protect the taxpayer from the risk of income assessment. In order to ensure reliability and accuracy of the studies, we use specialized databases provided by external suppliers, including databases used by tax control authorities. Being in possession of accurate benchmarking studies helps defend the taxpayer’s position, therefore minimizing the tax risk in case of a transfer pricing audit.

Benchmarking study vs new transfer pricing regulations

From 1 January 2017, preparing a benchmarking study will be obligatory for taxpayers who meet the criteria set out in the amendments to the Corporate Income Tax Act. These taxpayers will be obliged to prove that prices (margins, profits) in their transactions were set at a market level, i.e. the level that would have been accepted by independent entities acting in comparable conditions. With KPMG’s extensive experience in performing such analyses, we offer help in preparing, evaluating and updating benchmarking studies to every taxpayer.


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