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Dempe insights

Identifying intangibles and risks for DEMPE

In the 2017 edition of the Transfer Pricing Guidelines, the Organisation for Economic Co-operation and Development (OECD) outlines six steps for analyzing transactions involving intangibles. Step 1 is to “Identify the intangibles used or transferred in the transaction with specificity and the specific, economically significant risks

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DEMPE explained

The introduction of the concept of development, enhancement, maintenance, protection and exploitation of intangibles (DEMPE) has resulted in significant changes in how multinational enterprises (MNEs) implement the arm’s length principle…

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DEMPE functional analysis

The Actions 8–10 report by the Organisation for Economic Co-operation and Development (OECD), released in October 2015, states that the arm’s length principle requires that all members of the group receive appropriate compensation for any functions they perform, assets they use…

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DEMPE functions

Under the arm‘s length principle, each member of the multinational enterprise group should receive arm‘s length compensation for the functions it performs…

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DEMPE: six steps for analyzing transactions involving intangibles

Section 6.34 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (published by the OECD) outlines six steps for MNEs to follow when analyzing transactions involving intangibles…

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