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      Benchmark analyses are an important tool for proving the arm's length nature of transfer prices. It must be ensured that globally standardised criteria for the selection of comparable companies or transactions are applied within a group of companies for reasons of consistency and that a transparent and comprehensible process is used as a basis for the tax authorities.

      Our range of services

      KPMG prepares analyses tailored to your needs using your internal data as well as external data and information sources, which are generally subject to a charge. Our services include the following:

      • Global, regional and local database studies (e.g. AMADEUS, Compustat, Orbis) to determine ranges of appropriate profitability ratios for comparable companies, including the implementation of adjustment calculations (e.g. adjustment for economies of scale, working capital adjustments)
      • International database studies (e.g. ktMINE, RoyaltyStat) to determine ranges for licence or commission rates based on conditions contractually agreed between third parties or information on purchase price allocations
      • Determination of ranges for customary third-party 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. using Moody's RiskCalc or derived from 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
      • Preparation of econometric analyses, e.g. to prove the statistical robustness of database studies carried out and to prepare internal company data as the basis for an arm's length analysis
      assessment

      KPMG Atlas

      Documenting the arm's length nature of transfer prices for tax purposes

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      Global Transfer Pricing Services

      We have specialised in tax solutions for the design of transfer pricing systems.
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      Your contact

      Michael Freudenberg

      Partner, Tax - Head of Global Transfer Pricing Services

      KPMG AG Wirtschaftsprüfungsgesellschaft