AI is changing the audit baseline: tax authorities and reviewers can scrutinize benchmarking studies at much greater scale.
A TNMM benchmark is a chain of judgment calls, not a database exercise. Weaknesses usually start in the functional profile and search design.
Comparable selection should focus on value drivers: reject quickly, review real differences, and accept imperfect companies only when the differences are not material.
Range selection should reflect confidence in the comparables. A full range requires much stronger comparability than an interquartile range.
PLI selection is not just a formula. The cost base has to follow the tested party's functions, assets, risks, and accounting reality.
