Significance of the Comparability Analysis in the Transfer Pricing Report

The subject of the research is a comparability analysis that has to be done in order to completely apply the arm’s length principle and to properly do transfer pricing report by any of three methods (standard - transactional - methods, profit methods or other methods). The aim of the study is to underline the significance of a comparability analysis, especially from the aspect of answering numerous questions that arise during the preparation of the transfer pricing report. Some of the relevant answers are: the consistency of the comparability between controlled and uncontrolled transactions, correlation of the result obtained with the company strategy or contractual terms, use of the comparative analysis in the best way to complete transfer pricing report. The main hypothesis, which has been proven through the work, is that part of the comparability analysis (analysis of comparative conditions) can become the method for checking transfer prices.