What benchmarking is actually trying to establish

Benchmarking exists to answer one question: would unrelated parties have agreed to similar pricing for a similar transaction, under similar circumstances? The method chosen is simply the analytical approach best suited to answering that question for the specific type of transaction being examined.

The main methods, briefly

How the choice is generally made

The selection depends on the nature of the transaction, the availability of reliable comparable data, and the degree of comparability that can be established. In practice, TNMM is used for a large share of routine transactions (like distribution or contract manufacturing arrangements) simply because reliable direct-price comparables are hard to find, while CUP is preferred wherever a genuinely comparable market price is available.

Why the comparable set matters as much as the method

Even the right method produces a weak result if the comparable companies or transactions used aren't genuinely similar in function, risk profile, and market. A defensible benchmarking study spends as much effort justifying the comparable set as it does on the mechanical calculation itself.

This article provides general guidance for educational purposes and reflects our understanding of the law as of the publication date. It is not a substitute for professional advice tailored to your specific facts. Tax and regulatory provisions change, and thresholds/deadlines should always be verified at the time of action. Please speak with our team before relying on this for a specific decision.
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CR
CA Rajesh Bhagat
International Tax Partner · VRKSJP & Co

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