Together with David Zářecký, we have devised a practical approach for one of our clients to benchmark complex intercompany settlements among related investors in a real estate development project. The use of traditional OECD methods was not possible due to lack of publicly available data. TNMM was not considered viable, as it is best suited to benchmark ongoing transactions rather than one-off developments. The use of profit split was deemed too subjective, as quantifiable profit drivers could not be found. In the end, we opted for a valuation approach based on measuring the Internal Rate of Return (IRR) of the given real estate project after intercompany settlements. The clear advantage of IRR is that it is the preferred metric in real estate industry among investors looking at project viability in general, so it fully aligns the internal business and management point of view with the testing for tax purposes. Comparables can be readily obtained from public sources such as INREV, which regularly publishes European-wide data on performance of real estate vehicles in terms of IRR.