Secret comparable

Tax Glossary Definition

Secret comparable

A secret comparable refers to a transaction or entity used by tax authorities as a benchmark in a transfer pricing analysis, where the underlying financial data is not disclosed to the taxpayer. Such comparables are known only to the tax administration and are often criticized for lack of transparency, as they prevent the taxpayer from independently verifying whether the arm’s length principle has been properly applied.

Example: If a tax authority adjusts a company’s transfer pricing using confidential financial data from another enterprise that the taxpayer cannot access, that undisclosed entity is treated as a secret comparable.

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