Risk Matrix Approach in Selecting Comparable Parties for Transfer Pricing Benchmarking: A Practical Framework for Multinational Enterprises

This study examines the use of a risk matrix as a risk management framework for selecting comparable parties in transfer pricing benchmarking within multinational enterprises. Using a qualitative legal-practical approach, it analyses the OECD Guidelines (2022), academic literature and illustrative case studies. The findings show that a likelihood-impact risk matrix enables systematic screening of comparables: low-risk comparables form a core set, medium-risk comparables are retained with caution and high-risk comparables are excluded. This approach strengthens documentation, enhances transparency and reduces dispute and compliance risks, contributing to both transfer pricing theory and practice.