Transfer Pricing US CPM benchmarks

We are experts in delivering robust US CPM benchmarks, ready for audit and compliant with IRS guidelines

 

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Human Expertise    x    AI Power     for    better US CPM Benchmarks

Our CPM benchmarks combine experienced transfer pricing analysis with technology that enhances reliability and consistency.
We use AI-assisted tools to support peer screening and document traceability, while keeping expert judgment at the core of every engagement. This ensures the comparables selected match the tested U.S. entity’s functional profile and meet IRS scrutiny.

Each benchmark is performed by senior economists using US-specific company data and adapted to the functional risks of your entity.
We comply with IRS Section 482 guidance, and our reports are fully aligned with U.S. documentation standards for audit-readiness.

How we work

Step 1

Kickoff & Functional Analysis

Clarify entity profile, tested party, and select appropriate PLI (Operating Margin, ROA, Berry Ratio)

Step 2

Data Gathering & Peer Screening

Extract information from company 10-Ks. Select & reject comparables

Step 3

Arm’s Length Computation

Compute interquartile ranges for selected PLIs with clear adjustments and rationale

Step 4

Final Report

Deliver structured, IRS-ready documentation

Fast Turnaround Time

We follow a straightforward process allowing us and our clients to waste no time.

We usually provide an interquartile range for selected comparable companies in 10 working days (from initial call to first results).

We guarantee on-time delivery in a pre-agreed timeframe.

Tailored CPM Benchmarks

Complete, defensible documentation

At the start of your project, we define the right scope and PLI for your U.S. entity, depending on its functions, assets and risks.

We do not reuse old benchmarks. We use the latest comparable companies’ financials.

Every CPM report includes:

  • A detailed rejection matrix for rejected companies

  • Summary and financial profile of each selected comparable

  • IRS-ready interquartile range (and logic for PLI choice)

  • 10-K reports for each compable company reviewed, as well as additional information when needed (with urls of all sources)

We build reports you can defend, internally and in front of tax authorities.

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Expert Support

Our skilled team of economists and AI experts is consistently on hand to offer guidance and support during the benchmarking process.

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Q&A

I’m not a transfer pricing practitioner – what are we talking about?

You want to know all the basics, check our guide to comparable company searches! The guide focuses on European TNMM benchmarks, but the underlying mechanics is similar.

For which Transfer Pricing methods are these benchmarks needed?
  • Comparable company searches (also called benchmarks) are a specific transfer pricing analysis, aiming at identifying a set of independent companies comparable to the tested party.
  • Transactional methods such as the Comparables Profit Method (CPM) almost always require to perform a comparable company search. The comparable company search will serve as an external reference point for the net margin of the testing party (usually performing routine functions).
  • For traditional methods, comparable company searches are sometimes required, but less frequently.
What are the differences with benchmarks proposed elsewhere?

  • All benchmarks are prepared by highly experienced transfer pricing economists with over 10 years of expertise in producing audit-ready analyses.

  • Better and faster processes thanks to our algorithms trained to help the realization of comparable company searches. As a result, we propose benchmarks that meet the highest industry standards.

  • We also offer detailed documentation on our search processes and comparable selection, including annual reports for all accepted and rejected companies.
Where are the benchmarks performed? By whom?

Our comparable company searches are performed in France by our transfer pricing experts, assisted by our proprietary software.

Which database are you using?
  • We primarily rely on data published on the SEC database.
Any other question?

Do not hesitate to contact us: info@tpqube.com. It will be our pleasure to help you.

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