There are various sources of information that can be used to identify potential external comparables. This sub-section discusses particular issues that arise with respect to commercial databases, foreign comparables and information undisclosed to taxpayers. Additionally, whenever reliable internal comparables exist, it may be unnecessary to search for external ones, see paragraphs 3.27-3.28.
TPG2017 Chapter III paragraph 3.29
Category: A. Performing a comparability analysis, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Commercial databases, Comparability analysis, Comparable Uncontrolled Price (CUP) Method, Comparables, Databases, External comparables, Secret comparables« Prev | Next »
TPG2017 Chapter III paragraph 3.34
There are also proprietary databases that are developed and maintained by some advisory firms. In addition to the issues raised above for commercial databases that are...TPG2017 Chapter III paragraph 3.33
Use of commercial databases should not encourage quantity over quality. In practice, performing a comparability analysis using a commercial database alone may give rise to concerns...TPG2017 Chapter III paragraph 3.32
It may be unnecessary to use a commercial database if reliable information is available from other sources, e.g. internal comparables. Where they are used, commercial databases...TPG2017 Chapter III paragraph 3.31
A number of limitations to commercial databases are frequently identified. Because these commercial databases rely on publicly available information, they are not available in all countries,...TPG2017 Chapter III paragraph 3.30
A common source of information is commercial databases, which have been developed by editors who compile accounts filed by companies with the relevant administrative bodies and...
TP case laws
Germany vs “A Investment GmbH”, June 2017, Tax Court , Case no 10 K 771/16