Plain English
You cannot benchmark against companies you cannot see. Benchmarking databases like Orbis (global, published by Bureau van Dijk/Moody's) or Amadeus (Europe-focused) aggregate filed financial statements, industry classifications and ownership data for millions of companies, letting analysts search by geography, sector, size and independence to build a comparables shortlist. The database does the heavy lifting of scale; the analyst still has to read the individual business descriptions to confirm real comparability, because coding is often inconsistent or incomplete.
Technical definition
A structured commercial dataset compiling statutory financial statements, ownership structures and industry classification codes for private and public companies, used as the primary sourcing tool for the quantitative screening stage of a comparable search under OECD Transfer Pricing Guidelines Chapter III.
Why it matters
The database chosen affects which comparables are even visible, which in turn shapes the range. Tax authorities scrutinise database choice and coverage, particularly where a country-specific database exists but a broader regional one was used instead, or vice versa.
How it works in practice
- 01Select the database matching the geographic scope of the analysis.
- 02Apply industry classification filters (NACE, SIC, or the database's own codes).
- 03Filter for independence status to exclude companies that are themselves part of a group and could be controlled.
- 04Apply financial screens: minimum revenue, positive equity, no persistent losses.
- 05Export the shortlist for manual qualitative review against business descriptions.
Worked example
Choosing between Orbis and a local registry
An advisor benchmarking a Brazilian contract manufacturer initially runs a global Orbis search, returning 60 candidates, mostly non-Brazilian. Because local reviewers expect Brazilian or, failing that, Latin American comparables, the search is re-run restricted to the region, dropping to 14 candidates, of which 6 survive qualitative review. Using the unrestricted global set would likely have drawn a query from the Brazilian tax authority questioning geographic comparability, even if the statistical range looked similar.
Common mistakes
- Treating database industry codes as a reliable proxy for functional comparability without reading descriptions.
- Not disclosing which database and extraction date were used.
- Ignoring stale or unrestated financial data for comparables that later revised prior-year figures.
Audit red flags
- Comparables list with no extraction date or version noted.
- A database chosen that has materially poorer coverage of the relevant jurisdiction than an available alternative.
- Independence flags not checked, allowing group-affiliated companies into the comparables set.
Documentation & data
Documents to hold
- Database name, version and extraction date.
- Screening criteria applied, in the exact order run.
- Export files retained for the retention period required locally.
Data you need
- Subscription access to the relevant database(s).
- Industry classification for the tested party.
- Independence threshold policy to apply consistently.
Who owns this internally: Advisors typically hold the subscription and run searches; in-house teams increasingly license access directly for high-volume benchmarking.
Jurisdiction notes
- Europe
- Amadeus and Orbis are widely accepted by tax authorities across the EU, with country-level supplements sometimes preferred.
- Latin America
- Some authorities, notably in Mexico and Brazil, have historically pushed back on foreign comparables where local company data exists.
- United States
- Compustat and RoyaltyStat are common alternatives, particularly for public-company and royalty-rate searches.
Notes by role
Students & job seekers
Knowing the name and rough coverage of two or three major databases signals practical exposure in interviews.
In-house tax teams
Budget for the subscription cost when planning documentation cycles — it is a recurring line item, not a one-off.
Frequently asked
- Is one database always preferred?
- No — the appropriate database depends on the jurisdiction and transaction; some tax authorities specify or favour particular sources in local guidance.
- Do databases include private company data?
- Yes, this is their main value over public-market data sources, since most comparables in TP work are privately held companies filing local statutory accounts.
Sources & status
- Primary source
OECD Transfer Pricing Guidelines, Chapter III, paragraphs 3.29-3.34
OECD, 2022
- Our interpretation
Commercial database coverage and selection practice
This glossary, 2026
Reference material only, not advice on a specific fact pattern. Reviewed 2026-06-30.
Careers
How this shows up in the job
Database fluency (screen logic, export handling) is a concrete, trainable skill that differentiates candidates in entry-level TP roles.
Careers in transfer pricing