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Benchmarking studies provide evidence that your intercompany pricing is at arm’s length by comparing your transactions to similar transactions between unrelated parties.

Why benchmarking matters

Tax authorities may challenge your transfer pricing if they believe intercompany transactions are not priced at arm’s length. Benchmarking studies provide the economic analysis to support your pricing decisions.

Tracking benchmarking studies

Go to Transfer Pricing and click the Benchmarking tab to view and manage your studies. For each study, you can track:
  • Scope — which entities and transactions are covered
  • Methodology — the benchmarking approach used
  • Results — the arm’s length range and where your pricing falls
  • Date — when the study was conducted
  • Supporting documents — the full benchmarking report and data

Requesting a benchmarking study

If you need a new benchmarking study, you can request one through Commenda’s service marketplace. Professional advisors will conduct the analysis and deliver the results directly to your Commenda account.

Generating a benchmark automatically

For supported transaction types, you can generate a benchmarking study directly from a benchmark record instead of requesting one through the marketplace. Commenda submits the details of the intercompany transaction to our benchmarking provider, which returns an arm’s length range based on comparable third-party data. Use automated generation when you want a faster, self-service benchmark and the transaction fits one of the supported categories below. For complex or unusual arrangements, the marketplace route with a human advisor is still recommended.

Supported transaction types

Pick the transaction type that best describes the intercompany arrangement between the service provider entity and the counterparty:
  • Distribution — one entity buys goods from a related entity and resells them.
  • Manufacturing — one entity manufactures goods for a related entity.
  • Services — one entity provides services (e.g., management, technical, support) to a related entity.
  • Finance — intercompany loans, cash pooling, or other financing arrangements.
  • Royalty — licensing of intellectual property between related entities.

How it works

1

Open the benchmark

Go to Transfer PricingBenchmarking and open the benchmark you want to generate a study for. Make sure the service provider and counterparty entities are set and the relevant fiscal year is selected.
2

Choose a transaction type

Select the transaction type that matches your intercompany arrangement. Commenda will prompt you for the details required for that category.
3

Submit for generation

Submit the request. Commenda sends the transaction details to the benchmarking provider and stores the request and response on the benchmark for audit.
4

Review results

Once processing completes, the benchmark shows the generated arm’s length range and comparable data. You can attach the generated report as supporting documentation.
Each benchmark can be submitted for generation once successfully. If a submission fails due to missing or invalid inputs, fix the inputs and retry — previous failed attempts do not block a retry. If a submission has already succeeded, create a new benchmark record to run another study.
Only the sub-object that matches the selected transaction type is required. For example, if you choose distribution, fill in the distribution details; do not submit unrelated sub-objects. Mismatched inputs are rejected before submission.