Welcome
Welcome to the project website of InterQuartileRange
InterQuartileRange is a project by the Chair of Business Taxation at the University of Augsburg.
Funding
The project is generously funded by the Dr. Werner Jackstädt Foundation.
About InterQuartileRange
InterQuartileRange is a nonprofit project by the Chair of Business Taxation at the University of Augsburg. This project was made possible by the generous financial support of the Dr. Werner Jackstädt Foundation. Any transfer pricing documentation must demonstrate that the taxpayer has considered the arm’s length comparability of the applied transfer prices. Most tax authorities consider the precise analysis of publicly available financial statement data of so-called benchmark firms to be the state-of-the-art process in demonstrating that such an unbiased consideration has occurred. Such analyses require specific know-how and are often costly. Respective know-how and financial resources might not be available to any firm, particularly not to small and medium-sized firms. InterQuartileRange provides a standardized analysis tool to generate a reasonable assessment of an arm’s length range of transfer prices in these cases. For firms with the specific know-how available to conduct an in-depth analysis of their specific tax case, InterQuartileRange can provide a tool to conduct sensitivity analysis efficiently.
InterQuartileRange makes the distributions of the most common profit level indicators available. These distributions are comprehensively computed in accordance with internationally accepted transfer pricing regulations. The underlying computation algorithm of InterQuartileRange was designed with great attention to accuracy and in accordance with the highest technical and academic standards. Because of its necessarily high level of standardization, InterQuartileRange does not provide a case-specific transfer pricing assessment that considers all aspects of a given business transaction. Hence, professional interpretation and case-specific adjustment of the distribution of profit level indicators provided by InterQuartileRange may be necessary.
About the InterQuartileRange Analysis Tool
Below, background information about the analysis tool created by InterQuartileRange is provided. In particular, the analysis tool’s underlying institutional tax background is presented, the analysis tool’s methodology explained, information about the analysis tool’s used data given, and the analysis tool’s possible filter criteria that can be selected for the InterQuartileRange analysis tool are described.
Institutional Tax Background
From an economic point of view, an inevitable characteristic of transfer prices is that they are not derived under market mechanisms. More specifically, individual firms of a multinational group often do not have conflicts of interest in their intragroup negotiations with one another. Consequently, tax authorities around the globe scrutinize the transfer pricing structures of multinational groups. Any transfer pricing documentation must demonstrate that the taxpayer has considered the arm’s length comparability of its transfer prices. If a firm has not prepared (sufficient) transfer pricing documentation, tax authorities can presume that the actual income generated is higher than the income declared by the firm, which will regularly result in an increase in taxable income in that country. In addition, penalties may be imposed.
However, “transfer pricing is not an exact science”[1]. Consequently, for each business transaction, there will always be several arm’s length prices, i.e., several transfer prices that third parties would have agreed on under comparable circumstances.[2] Thus, there is no unique “correct” transfer price. Consequently, a key aspect in transfer pricing determination and documentation is the assessment of the relevant limits of a range of transfer prices.
To assess such a range of transfer prices, comparable business transactions are required. The transfer prices of the taxpayer are compared with the arm’s length prices observed from comparable uncontrolled business transactions either 1) with third parties (internal comparison) or 2) between third parties (external comparison).[3] If the business transaction is perfectly comparable, all available arm’s length prices can be used as a basis for determining the transfer price. If business transactions are only comparable to a limited extent, transfer pricing analyses calculate narrowed ranges of transfer prices to prevent the selection of transfer prices that are too extreme.[4]
In transfer pricing analyses, financial statement data are used to identify firms whose business transactions are comparable to those of the taxpayer and are not part of a multinational group (so-called benchmark firms). The profit level indicators realized in these business transactions of the benchmark firms can be compared with the respective intragroup transfer prices of the taxpayer to document their at arm’s length transfer prices.
[1] OECD Transfer Pricing Guidelines, 2017 (hereafter “OECD TP Guidelines 2017”), para. 1.13.
[2] OECD TP Guidelines 2017, para. 3.55 ff.
[3] OECD TP Guidelines 2017, Glossary: “Comparable uncontrolled transaction”.
[4] OECD TP Guidelines 2017, para. 3.20.
Methodology
General
InterQuartileRange provides a transfer pricing analysis tool with a high level of standardization. It specifically aims to comprehensively compute relevant quantiles, relevant profit level indicators, relevant industry groups and relevant estimation methods. The overarching goal is to provide firms with a wide range of arm’s length prices that are accurately computed in accordance with the highest technical and academic standards. The InterQuartileRange analysis tool is free of charge. It enables firms 1) to generate a reasonable estimate of transfer prices in any given transaction and 2) to conduct sensitivity analyses as part of their overall transfer pricing assessments. InterQuartileRange is not aimed at providing a substitute for case-specific transfer pricing analyses in cases of high stakes business transactions. InterQuartileRange also does not provide case-specific transfer pricing analyses or consulting services of any kind.
Profit Level Indicators
The InterQuartileRange analysis tool calculates profit level indicators in accordance with the selected filter criteria. To exclude outliers, the range of profit level indicators are usually narrowed. The internationally most commonly use of such a narrowed range of profit level indicators is the interquartile range (i.e. exclusion of 25% of the smallest and 25% of the largest arm’s length profit level indicators). Because different tax authorities also accept different narrowed ranges of profit level indicators, the InterQuartileRange analysis tool provides all quantiles of the respective profit level indicators for each analysis.[1]
Estimation Uncertainties
Estimations as the computation of the narrowed ranges of the interquartile range inevitably give rise to estimation uncertainties. Hence, it is necessary to explicitly compute a measure of estimation uncertainties for the point estimators of the interquartile range. However, different countries treat such uncertainties in a different way. Accordingly, allowing uncertainties being taken appropriately into account, the InterQuartileRange analysis tool provides the 95% confidence intervals of the 25%, the 50% (median), and the 75% quartile point estimators of the interquartile range for each analysis to mention the respective margin of statistical uncertainty. The 95% confidence interval shows a range of values around the quartiles’ point estimators. The true value of the respective quartile’s point estimator - and therefore the upper or lower limitation of the interquartile range - lies within this range of values by a probability of 95%.
To document the findings of a respective transfer pricing analysis, the InterQuartileRange analysis tool provides the possibility to download a Transfer Pricing Report after such a transfer pricing analysis has been computed. The Transfer Pricing Report includes all necessary background information of the InterQuartileRange analysis tool, the chosen filter criteria, and the computed results to give a stand-alone insight into the respective analysis. Furthermore, each Transfer Pricing Report can be downloaded again on the InterQuartileRange website by a unique identifier included in the Transfer Pricing Report.
[1] OECD TP Guidelines 2017, para. 3.57.
Data
InterQuartileRange uses Bureau van Dijk’s balance sheet database Amadeus VLLM (very large, large and medium-sized firms), accessed via Wharton Research Data Service. Only firms with a consolidation code of U1 or U2 are included. Overall, the data received from Bureau van Dijk for the InterQuartileRange analysis tool contain approximately 2.4 million firms, geographically located in 42 countries in Europe.
The current data were updated by Bureau van Dijk and uploaded into the InterQuartileRange analysis tool on September 14, 2021.
The following table shows the frequencies of firms that are included in the InterQuartileRange analysis tool for each country with data for profit level indicators of at least one year in the period 2014 until 2020.
Filter Criteria
Years
The InterQuartileRange analysis tool allows the selection of specific years to be included in the analysis. The analysis can be conducted for a single year or multiple years.
If a specific firm does not provide data for all selected years, only the years available are included for that firm in the transfer pricing analysis. Alternatively, by activating the button “Include a firm only when data are available for all selected years.” firms are only included when data for all selected years are available.
By activating the button “Include firm-years only when the operating profit is equal to or greater than zero (=exclude loss-years).” firms' data are only included with a nonnegative operating profit in the respective year from the transfer pricing analysis.
Countries
The InterQuartileRange database allows the selection of countries where the firms to be analyzed shall be located.
NACE
The InterQuartileRange analysis tool allows the selection of industry groups as indicated by NACE codes (Nomenclature of Economic Activities) in which the firms to be analyzed shall be active. The tool also allows the selection of specific aggregations of NACE codes.
NACE codes consist of a four-digit number. The digits' positions within this number explain a different level of detail of the firm’s industry group. A digit at a leading position within the NACE code describes the industry group more roughly than at a rear position within the NACE code. The InterQuartileRange analysis tool allows an individual selection of the level of detail regarding the industry groups to be analyzed based on the number of digits in leading positions of the NACE code. By selecting a NACE code with fewer than four digits, all NACE codes within the coarser NACE code (NACE codes beginning with the selected NACE code) are included in the transfer pricing analysis.
Independence
The InterQuartileRange analysis tool allows the selection of independence indicators to identify the firms to be analyzed.
The independence indicators are used as provided by Bureau van Dijk:
|
A+ |
6 or more identified shareholders, no shareholder(s) holds directly or indirectly more than 25% ownership (direct or collective) |
|
A |
4 or 5 identified shareholders, no shareholder(s) holds directly or indirectly more than 25% ownership (direct or collective) |
|
A- |
1 to 3 identified shareholders, no shareholder(s) holds directly or indirectly more than 25% ownership (direct or collective) |
|
B+ |
6 or more identified shareholders, no shareholder(s) holds more than 50% ownership, but 1 or more shareholder(s)more than 25% ownership |
|
B |
4 or 5 identified shareholders, no shareholder(s) holds more than 50% ownership, but 1 or more shareholder(s) more than 25% ownership |
|
B- |
1 to 3 identified shareholders, no shareholder(s) holds more than 50% ownership, but 1 or more shareholder(s) more than 25% ownership |
|
C+ |
Any company with a recorded shareholder that has a total or calculated ownership with more than 50% |
|
C |
Any company with a recorded shareholder that has a summation of direct ownership of with more than 50.01% |
|
D |
Any company with a recorded shareholder with a direct ownership with more than 50% |
|
U |
Degree of independence is unknown |
Firm Size
The InterQuartileRange analysis tool allows the selection of firm size indicators to identify the firms to be analyzed.
The firm size indicators are used as provided by Bureau van Dijk:
|
Very Large |
Operating Revenue ≥ EUR 100 million |
|
Large |
Operating Revenue ≥ EUR 10 million |
|
Medium |
Operating Revenue ≥ EUR 1 million |
Alternatively, InterQuartileRange allows the selection of a more granular size filter based on firm-year-level annual turnover.
Activity
The InterQuartileRange analysis tool allows the selection of activity indicators to identify the firms to be analyzed.
An “active” firm is still in business, while a “passive” firm no longer performs its regular business activities.
Data Preparation Method (DPM)
General
The InterQuartileRange analysis tool allows a variety of mathematical-statistical methods.
Multiple methods exist for the point estimation of quantiles.[i] Method choice can considerably affect the arm’s length interquartile range, especially in the case of small samples and wide dispersion within the data, as is common in the transfer pricing context. In addition, there are several different procedure choices for preparing raw data when data from multiple years shall be analyzed.[ii] InterQuartileRange provides four different procedure choices of calculation in the case of a multiple-year analysis (DPM) and nine different methods to compute point estimates of sample quantiles (QCM).[iii]
The four different procedure choices of calculation in the case of a multiple-year analysis (DPM) are defined as follows:
|
DPM |
Calculation |
|
Simple Average |
(x1+x2+…+xn) / n |
|
Weighted Average |
(x1y1+ x2y2+x3y3…..+xnyn) / (y1 +y2+y3+…+yn) |
|
Pooling |
(x11+x12+x13+…+x21+x22+x23+…+xij) / (i*j) |
|
Pooling (T-adjust, U-adjust)[iv] |
((x11-Øt1-ØU1+2*ØTU)+(x12-Øt1-ØU2+2*ØTU)+…+((xij-Øti-ØUj+2*ØTU)) / (i*j) |
[i] For an overview of possible approaches, cf. Hyndmann/Fan, 1996, p. 361 ff.
[ii] Cf. Ullmann/Trede, 2015, p. 329 ff.
[iii] Definitions taken from https://stat.ethz.ch/R-manual/R-devel/library/stats/html/quantile.html; for further details, cf. Hyndman/Fan, 1996, p. 361 ff.
[iv] Cf. Ullmann/Trede, 2015, p. 329 ff.
Quantile Computation Method (QCM)
General
The InterQuartileRange analysis tool allows a variety of mathematical-statistical methods.
Multiple methods exist for the point estimation of quantiles.[i] Method choice can considerably affect the arm’s length interquartile range, especially in the case of small samples and wide dispersion within the data, as is common in the transfer pricing context. In addition, there are several different procedure choices for preparing raw data when data from multiple years shall be analyzed.[ii] InterQuartileRange provides four different procedure choices of calculation in the case of a multiple-year analysis (DPM) and nine different methods to compute point estimates of sample quantiles (QCM).[iii]
The nine different methods to compute point estimators (QCM) are as follows:
|
General Properties (QCM1 - QCM9) |
|
|
For all nine sample quantile types applies: Q[i](p) = (1 - γ) x[j] + γ x[j+1], where 1 ≤ i ≤ 9, (j-m)/n ≤ p < (j-m+1)/n, x[j] is the jth order statistic, n is the sample size, the value of γ is a function of j = floor(np + m) and g = np + m - j, and m is a constant determined by the sample quantile type. |
|
|
Discontinuous Sample Quantile Types (QCM1 - QCM3) [iv] |
|
|
QCM1 |
Inverse of empirical distribution function. γ = 0 if g = 0, and 1 otherwise. |
|
QCM2 |
Similar to type 1 but with averaging at discontinuities. γ = 0.5 if g = 0, and 1 otherwise. |
|
QCM3 |
Nearest even order statistic. γ = 0 if g = 0 and j is even, and 1 otherwise. |
|
Continuous Sample Quantile Types (QCM4 - QCM9) [v] |
|
|
QCM4 |
m = 0. p[k] = k / n. That is, linear interpolation of the empirical cdf. |
|
QCM5 |
m = ½. p[k] = (k - 0.5) / n. That is a piecewise linear function where the knots are the values midway through the steps of the empirical cdf. This is popular amongst hydrologists. |
|
QCM6 |
m = p. p[k] = k / (n + 1). Thus p[k] = E[F(x[k])]. |
|
QCM7 |
m = 1-p. p[k] = (k - 1) / (n - 1). In this case, p[k] = mode[F(x[k])]. |
|
QCM8 |
m = (p+1)/3. p[k] = (k - 1/3) / (n + 1/3). Then p[k] =~ median[F(x[k])]. |
|
QCM9 |
m = p/4 + 3/8. p[k] = (k - 3/8) / (n + ¼). |
[i] For an overview of possible approaches, cf. Hyndmann/Fan, 1996, p. 361 ff.
[ii] Cf. Ullmann/Trede, 2015, p. 329 ff.
[iii] Definitions taken from https://stat.ethz.ch/R-manual/R-devel/library/stats/html/quantile.html; for further details, cf. Hyndman/Fan, 1996, p. 361 ff.
[iv] For types 1, 2 and 3, Q[i](p) is a discontinuous function of p, with m = 0 when i = 1 and i = 2, and m = -½ when i = 3.
[v] For types 4 through 9, Q[i](p) is a continuous function of p, with gamma = g and m given below. The sample quantiles can be obtained equivalently by linear interpolation between the points (p[k],x[k]) where x[k] is the kth order statistic. Specific expressions for p[k] are given below.
Profit Level Indicator
The InterQuartileRange database allows the selection of four different profit level indicators to be included in the transfer pricing analysis for analyzing the firms' data:
| PLI | Calculation |
|---|---|
| Operating Margin | Operating Profit & Loss / Operating Revenue |
| Gross Margin | (Operating Revenue - Cost of Goods Sold) / Operating Revenue |
| Berry Ratio | Gross Profit / Operating Expenses |
| Net Cost Plus Mark-Up | Operating Profit & Loss / (Operating Revenue - Operating Profit & Loss) |
InterQuartileRange Analysis Tool
To create a transfer pricing analysis on InterQuartileRange, please first select filter criteria in the filter input section below that fit with your interests. Definitions of the respective filter criteria can be accessed by clicking the “?” buttons.
After selecting the applicable filter criteria, the analysis can be requested by clicking “Compute Analysis” button. The results are displayed immediately or can be downloaded as an InterQuartileRange Transfer Pricing Report by clicking the “Download Report” button.
To save the settings of a specific transfer pricing analysis, it is possible to create a bookmark. In this case, a URL link will be created with which the respective filter criteria selection is saved. The URL link can be requested by clicking on the “Set Bookmark” button.
Please be aware that, depending on your request, the analysis may take up to several minutes. Please do not leave the website during the computation time.
Analysis Output Section
Filter Criteria
The following filter criteria are included in the current analysis:
Results of the InterQuartileRange Analysis
The following figure shows the interquartile bandwidths of the transfer pricing analyses requested.
The 25%-Quartile (Q25), the Median (Q50), and the 75%-Quartile (Q75) are shown as data points in the figure. The whiskers around the quartiles' data points show their respective 95% confidence intervals (CI).
Results in Detail
The quantiles as results of the transfer pricing analysis are shown in the following table in detail.
The values are presented in %.
Report Archive
InterQuartileRange archives all InterQuartileRange Transfer Pricing Reports for at least ten years. Each database analysis has an individual Identifier Code. The Identifier Code can be used to prove to tax authorities at any time that a specific database analysis has in fact, been provided by InterQuartileRange, relying on the data and analytical methodology available at a specific time.
The specific InterQuartileRange Transfer Pricing Report can be downloaded again by using the individual Identifier Code.
Please note that a recently created InterQuartileRange Transfer Pricing Report can take up to 24 hours until being available for a download here.
Legal Notice
Information according to ยง 5 TMG
University of Augsburg
Faculty of Business and Economics
Chair of Business Taxation
Prof. Dr. Robert Ullmann, StB/CFA
Building J, Room 1307
Universitätsstr. 16
D-86159 Augsburg
Do not hesitate to contact us via tax@wiwi.uni-augsburg.de
Legal Form and Representation
InterQuartileRange is a project of the Chair of Business Taxation at the University of Augsburg. The University of Augsburg is a public corporation and state institution (Art. 11 para. 1 BayHSchG). It is legally represented by its President.
Supervisory Authority in Charge
Bavarian State Ministry for Science and Art
Salvatorstr. 2
80333 Munich
Consumer Dispute Resolution/Universal Mediation Body
InterQuartileRange is not prepared or obliged to participate in dispute resolution proceedings at a consumer arbitration board.
Liability of Contents
As a service provider, InterQuartileRange is responsible for its content on these pages according to § 7 para.1 (German Telemedia Act - TMG) and general laws. According to §§ 8 to 10, TMG InterQuartileRange is not obliged to monitor transmitted or stored information from third parties or investigate circumstances that indicate illegal activity. Obligations to remove or block the use of information according to general laws remain unaffected. However, in this respect, liability is only possible from the time of knowledge of a concrete infringement. If InterQuartileRange becomes aware of any such legal infringements, InterQuartileRange will remove the content in question immediately.
Liability for Links
InterQuartileRange’s offer can contain links to external websites of third parties, on whose contents InterQuartileRange has no influence. Therefore, InterQuartileRange cannot assume any liability for these external contents. The respective provider or operator of the sites is always responsible for the contents of the linked sites. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not identified at the time of linking. However, permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. If InterQuartileRange becomes aware of any infringements, InterQuartileRange will remove such links immediately.
Copyright
The contents and works on these pages created by the site operators are subject to German copyright law. Reproduction, editing, distribution and any use outside the limits of the copyright law require the written consent of the respective author or creator. Insofar as the content on this site was not created by the operator, the copyrights of third parties were observed. Third-party content is identified as such. Should you become aware of a copyright infringement, please inform InterQuartileRange accordingly. If InterQuartileRange becomes aware of any infringements, InterQuartileRange will remove such contents immediately.
Disclaimer
InterQuartileRange is a free of charge and not-for-profit transfer pricing database. The data, programming, and results were carefully tested. Nevertheless, no guarantee or liability can be assumed for the accuracy of the InterQuartileRange database analyses. Furthermore, InterQuartileRange does not provide tax consulting services of any kind.
Data Protection
General Notes
The following information provides a simple overview of what happens to personal data when visiting this website. Personal data are all data with which the users can be personally identified. For detailed information about data protection, please refer to the following data protection declaration.
Data collection on this website
Who is responsible for data collection on this website?
The contact details of the person responsible for data collection can be found in the website’s imprint.
How is the data collected?
The users’ data are collected when the users provide it to the InterQuartileRange team. These data can be data that the users send to the InterQuartileRange team by e-mail, for example.
We do not collect any data automatically when the users visit the website. The hoster (see below) may store data in the form of cookies. These cannot be viewed or used by the InterQuartileRange team.
What is the data used for?
We only use the users’ data if the users have contacted the InterQuartileRange team individually.
What rights do the users have regarding the data?
The users have the right to receive information free of charge at any time about the origin, recipient and purpose of their stored personal data. They also have the right to demand the correction or deletion of these data. For this purpose, and further questions regarding data protection, the users can contact the team of InterQuartileRange at any time at the e-mail address given in the imprint. Furthermore, users have the right to complain to the responsible supervisory authority.
Furthermore, users have the right to demand under certain circumstances the restriction of the processing of their personal data. Please refer to the data protection declaration under the “Right to limitation of processing” for details.
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This website is hosted by an external service provider (hoster). The personal data collected by the hoster are stored on the hoster’s servers, which may include IP addresses, contact requests, meta and communication data, and so on.
The data’s use by the hoster is for the purpose of fulfilling a contract with the potential and existing users (Art. 6 para. 1 lit. b General Data Protection Regulation - GDPR) and in the interest of a secure, fast and efficient provision of the online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).
General information and compulsory information
Data protection
We take the protection of the users’ personal data very seriously. We treat the users’ personal data confidentially and according to the legal data protection regulations and this privacy policy.
We do not collect any personal data during the use of the website.
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Many data processing operations are only possible with the users' express consent. They can revoke a previously given consent at any time. For this purpose, informal notification by e-mail to the InterQuartileRange team is sufficient.
The legality of the data processing carried out up to the time of revocation remains unaffected by the revocation.
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If the data processing is carried out based on Art. 6 para. 1 lit. e or f GDPR, the users shall have the right to object to processing their personal data at any time for reasons arising from their specific situation, including profiling based on these provisions. The respective legal basis on which processing is based can be found in these data protection declaration. If the users object, the InterQuartileRange team will no longer process the users' personal data, unless the InterQuartileRange team can prove that there are compelling reasons for processing that are worthy of protection and which outweigh the users’ interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims (objection according to Art. 21 para. 1 GDPR).
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The users have the right to have data, which we process automatically based on the users’ consent or in fulfilment of a contract handed over to the users or a third party in a common, machine-readable format. If the users request the direct transfer of the data to another responsible party, this will only occur to the extent that it is technically feasible.
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Within the framework of applicable legal provisions, users have the right to obtain information free of charge at any time about the users’ stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correct or delete these data. For this purpose, and for further questions regarding personal data, the users can contact the InterQuartileRange team at any time at the address given in the imprint.
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The users have the right to request the restriction of the processing of the users’ personal data.
To do so, the users can contact the InterQuartileRange team at any time at the address given in the imprint. The right to restrict processing exists in the following cases: If the users dispute the accuracy of the users’ personal data stored with the InterQuartileRange team, we usually need time to verify this. For the duration of the review, the users have the right to demand the restriction of processing of users’ personal data.
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Data collection on this website
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Contact
If you want to get in touch with us, please use the following contact formular.
Funding
We thank the Dr. Werner Jackstädt Foundation for its generous financial funding and support of the InterQuartileRange project.