Comparability analysis of market transactions

The comparability analysis of market transactions concerns a detailed analysis of transactions carried out between related entities and between independent entities. It covers a comparison of financial (including commercial) data in an internal form, known as an internal comparable (based on internal data for identical or similar transactions), or an external form, known as an external comparable (based on market data for comparable transactions). The purpose of the comparability analysis is to demonstrate the arm's length character of the transactions carried out between related entities, on the basis of the results achieved by those entities in comparable internal transactions or by independent entities in the case of an external comparison. Transactions are comparable if none of the differences between them could materially affect the factor taken into account in the methodology (e.g. price or margin), or if sufficiently accurate adjustments can be made to eliminate the material effects of such differences.