Benchmarking
Tested party selection, search design, quantitative and qualitative screening, adjustments, ranges and defending the Accept-Reject matrix.
Transfer Pricing Benchmarking: Methodology, Data & Worked Study (2026)
The end-to-end benchmarking study: scoping, search design, quantitative and qualitative screening, adjustments, the arm's length range and refresh — with a worked Indian case.
Read docTested Party Selection: The "Less Complex" Principle, Applied
How to pick the tested party in a TNMM study: the OECD "least complex" logic, the six-question test, the documentation trail, and the objections transfer pricing officers raise most.
Read docTP Benchmarking Databases Compared (India and Global Sources)
The benchmarking data sources an Indian study actually uses — Prowess, Capitaline, global databases, Big-4 industry studies, and public filings — with their strengths and gaps.
Read docBenchmark Search Design: NIC/NACE Codes, Size and Industry Filters
How to design a benchmark search that is neither too broad nor too narrow: the NIC-2008 code as the load-bearing filter, search strings, size proxies and the over/under-inclusion traps.
Read docQuantitative Screening: Filters, Order and Discipline (2026)
The quantitative comparable screen, filter by filter: size, profitability, sector and geography thresholds, the order to apply them, and the exclusion log that makes it audit-defensible.
Read docQualitative Screening: The Company-by-Company Review
How to run the qualitative comparable review: the five things to verify per company, the evidence hierarchy, and accept/reject notes that survive a transfer pricing officer.
Read docAI-Assisted Comparable Screening: How It Works
How AI-assisted comparable screening works in a benchmarking study — what the model evaluates, what it must cite, and the human controls that keep the Accept-Reject matrix defensible.
Read docWorking Capital Adjustments in Benchmarking
When and how to make working capital adjustments in Indian TNMM benchmarking — the DIO/DSO/DPO mechanics, formulas, and when the TPO expects them.
Read docHandling Extraordinary Events in Comparability
How to handle extraordinary and non-recurring events in Indian comparability analysis — one-off gains, COVID-style years, restructuring, and the treatment that survives TPO review.
Read docMulti-Year Averaging in TNMM: Simple, Weighted and Period Methods
Single-year vs multi-year data in TNMM: when the OECD requires looking beyond one year, how simple and weighted averages are computed, and when averaging masks a trend.
Read docIQR vs Full Range: Choosing the Arm's Length Range
OECD's interquartile range versus the full range: quartile math step-by-step, when each is defensible, the mid-point argument, and how to document the choice in India.
Read docLoss-Making Comparables: Keep, Adjust or Exclude?
The framework for loss-making companies in the comparable pool: temporary versus structural losses, the matching rule, missing data, and the documentation the TPO expects.
Read docRegional vs Local Comparables: Geographic Scope and Authority Views
When the comparable pool can extend beyond the local market: the OECD multi-regional rule, the tax-differential boundary, Indian TPO practice, and where authorities push back.
Read doc12 Common Benchmarking Mistakes (Self-Audit Checklist)
Twelve mistakes that fail benchmarking studies in examination — the wrong code, the mixed PLI, the silent loss-maker, the range shop — each with its consequence and the fix.
Read docDefending Your Accept-Reject Matrix Before the TPO (and IRS)
What the TPO and IRS actually scrutinize in the Accept-Reject matrix: the evidence file structure, the override rationale, the consistency tests, and the questions to rehearse.
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Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.