Beyond the Single Market: The Case for Clustering Cross-Border Comparables in Pan-European Comparability Studies

This article presents a stepwise methodology for reliable pan-European comparability analyses. It aims to provide a comprehensive framework that ensures consistency and accuracy across various European contexts. The structured five-phase approach includes database screening, quantitative filtering, manual review, comparability adjustments and interquartile range determination. Together, these steps ensure consistency, transparency and economic relevance across EU Member States. By integrating market clustering based on geography, GDP, labour costs and sovereign risk, the framework bridges the gap between OECD/EU policy and practical benchmarking. It offers practitioners and policymakers a coherent, data-driven path toward harmonized, audit-ready comparability analyses within the evolving European transfer pricing landscape.