Tranfer pricing audit

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Querist : Anonymous

Querist : Anonymous (Querist)

25 November 2013 WHAT WILL BE THE COMPARABLE PRICE FOR PAYMENT MADE FOR JOB WORK CHARGES TO ANY ASSOCIATED ENTERPRISE, IF THE ASSOCIATED ENTERPRISE IS DOING JOB WORK OF THE ASSESSEE ONLY AS WELL AS THE ASSESSEE IS PAYING TO THE SAME ASSOSSIATED ENTERPRISE ONLY FOR JOB WORK?
BUT THE RATE OF OTHER INDUSTRY IN SIMILAR BUSINESS IS NOT AVAILABLE THEN WHAT TO DO?

Nikhil Kaushik

Nikhil Kaushik (Expert)
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25 November 2013 you have to check the comparable pricing for similar transaction by other enterprises in the same business line with similar turnover size.

Querist : Anonymous

Querist : Anonymous (Querist)

25 November 2013 Thanks but my problem is modified in question

Nikhil Kaushik

Nikhil Kaushik (Expert)
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25 November 2013 friend, you need to look for transfer pricing portals which keep huge database for comparable prices and margins.

Querist : Anonymous

Querist : Anonymous (Querist)

25 November 2013 Plz give me ref. of that particular portal.

Querist : Anonymous

Querist : Anonymous (Querist)

25 November 2013 Plz give me ref. of that particular portal.

Aashok Kumar Sharma

Aashok Kumar Sharma (Expert)
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02 August 2025 For Transfer Pricing (TP) audit and finding comparables when industry rates or similar transactions are not readily available, here are some helpful resources and approaches:

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### 1. **Transfer Pricing Databases / Portals:**

Several paid and subscription-based databases provide data on comparable uncontrolled transactions, margins, and pricing. Some commonly used ones include:

* **Thomson Reuters ONESOURCE Transfer Pricing:**
Comprehensive database for comparable data and TP documentation.

* **Bloomberg TP Studio:**
Provides detailed financial and transaction data to identify comparables.

* **Bureau van Dijk (Orbis):**
Extensive company and financial data worldwide, useful to identify comparables.

* **Capital IQ (S\&P Global):**
Offers detailed company financials and transaction details.

* **PwC, Deloitte, EY, KPMG TP portals:**
Large consulting firms often have their own proprietary databases.

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### 2. **Government and Publicly Available Resources:**

* **Indian Transfer Pricing Search Portal:**
Income Tax Department’s portal for TP rulings, can give guidance but limited data.

* **OECD Transfer Pricing Guidelines:**
Useful for methodology and principles to identify comparables.

* **Company Annual Reports:**
Public companies’ filings may give useful financial data.

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### 3. **Practical Steps if No Direct Comparable:**

* **Use Industry Benchmarks:**
Even if exact job work rate is not available, look for margins or cost-plus percentages in similar industries.

* **Cost Plus Method:**
Calculate cost of job work plus reasonable mark-up, based on functions performed.

* **Broaden Search Parameters:**
Expand geographic or industry scope to find closest comparables.

* **Functional Analysis:**
Examine functions, assets, and risks of both entities to justify pricing.

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### 4. **Recommendations:**

* Subscribe to a TP database relevant for your jurisdiction and industry.

* Consult with TP experts or firms who have access to these databases.

* Document the methodology and reasons for selecting comparables thoroughly for audit defense.

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If you want, I can help you draft a Transfer Pricing search strategy or help interpret the guidelines based on your facts. Would you like that?

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