How To Conduct Effective Benchmarking For TP Purposes

When it comes to international trade and business operations, Singapore stands as a beacon of economic prowess. Its strategic location, business-friendly environment, and robust regulatory framework have attracted numerous multinational corporations (MNCs) to establish their regional headquarters here. Adhering to the transfer pricing guidelines in such a diverse and vibrant business landscape becomes imperative. Benchmarking, a pivotal aspect of transfer pricing, plays a crucial role in this regard.

Read on as we go over the intricacies of conducting effective benchmarking for transfer pricing purposes.

Understanding Transfer Pricing and Benchmarking

Transfer pricing refers to the pricing of goods, services, or intangible assets transferred within multinational companies. It ensures that transactions between related entities are conducted at arm’s length, akin to transactions between independent parties. Benchmarking serves as a method to determine whether the prices charged in intra-group transactions align with those observed in comparable transactions between unrelated parties.

1. Know your industry

Before delving into benchmarking exercises, it is crucial to comprehend the dynamics of the industry in which the company operates. Singapore hosts a wide array of industries, ranging from finance and technology to manufacturing and logistics. Each industry possesses its unique characteristics, market trends, and pricing structures. By gaining a deep understanding of the industry landscape, businesses can identify suitable comparables for benchmarking purposes.

2. Identify comparable transactions

Once the industry landscape is understood, the next step involves identifying comparable transactions or companies. In Singapore, the Inland Revenue Authority (IRAS) provides guidelines on selecting comparables, emphasising the importance of similarity in functions, risks, and assets. Companies should focus on finding entities that closely resemble their own in terms of business operations, geographic location, and market conditions.

3. Utilise reliable data sources

Accurate and reliable data serve as the cornerstone of effective benchmarking. In Singapore, companies can access a myriad of data sources, including publicly available financial statements, industry reports, and commercial databases. Additionally, engaging reputable third-party providers specialising in transfer pricing data can offer valuable insights and ensure compliance with regulatory requirements.

4. Analyse financial metrics

Benchmarking involves a meticulous analysis of financial metrics to ascertain compatibility between related and unrelated transactions. Key financial indicators such as profitability margins, return on assets, and working capital ratios play a pivotal role in this analysis. Companies should employ robust statistical techniques to normalise financial data and mitigate any discrepancies arising from differing accounting practices or economic conditions.

5. Consider functional and economic factors

Beyond financial metrics, benchmarking necessitates a comprehensive evaluation of functional and economic factors. This involves scrutinising the roles and contributions of related entities within the value chain, as well as assessing market dynamics, pricing strategies, and industry trends. By considering these qualitative aspects, companies can ensure a holistic comparison and substantiate their transfer pricing policies to tax authorities.

6. Document benchmarking analysis

Documentation holds immense significance in transfer pricing compliance, especially in Singapore, where regulatory scrutiny is rigorous. Companies must maintain detailed records of their benchmarking analysis, including the selection criteria, data sources, comparability adjustments, and rationale for the chosen method. This documentation not only demonstrates adherence to best practices but also facilitates effective communication with tax authorities during audits.

7. Monitor and update benchmarking studies

The dynamic nature of business environments necessitates periodic review and updating of benchmarking studies. Market conditions, regulatory changes, and technological advancements can significantly impact the comparability of transactions over time. Hence, companies should establish a framework for ongoing monitoring and adjustment of their transfer pricing policies to ensure alignment with prevailing market realities.


In the intricate landscape of transfer pricing compliance, mastering the art of benchmarking is indispensable for businesses operating in Singapore. Furthermore, proactive documentation and continuous monitoring ensure adaptability to evolving regulatory frameworks and market dynamics. Ultimately, adherence to best practices in benchmarking fosters trust and transparency in intra-group transactions, thereby sustaining Singapore’s reputation as a hub for international business excellence.

Max Lewis provides various services, from employee shares option services to valuation services in Singapore. We are proud recipients of highly acclaimed awards, such as the Best Transfer Pricing Advisory Specialists – Singapore award at the APAC Insider Southeast Asia Business Awards 2022. We are also a proud recipient of the Best Transfer Pricing Consultancy Firm of the Year award at the Corporate LiveWire Global Awards. Contact us now to explore the wide range of services we offer.

*The above represents our opinions and views and does not necessarily reflect the position of any entities mentioned.