DEMPE – Still a Long Way to Go

An integral part of the BEPS Action Plan is the Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE) concept, which is intended to ensure a fair allocation of profits stemming from transactions that involve intangible assets. However, even though the DEMPE concept was included in the OECD Transfer Pricing Guidelines, its impact on the activities and profits of MNEs remains unclear. A survey conducted in 2023 revealed differing attitudes to the impact of DEMPE on MNEs’ income distribution and business operations, indicating a growing awareness of the concept but also highlighting the importance of clearer guidance on its application and integration with existing transfer pricing methodologies.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2024-08-12
DOI
https://doi.org/10.59403/x67xfv
Citations
1
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.95
Controls
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article

DEMPE – Still a Long Way to Go

A. Riedl, O. Miakota
1 citations
International Transfer Pricing Journal
Corporate Taxation and Avoidance
0.95
article

DEMPE – Still a Long Way to Go

A. Riedl, O. Miakota
article en
1 citations

Abstract

An integral part of the BEPS Action Plan is the Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE) concept, which is intended to ensure a fair allocation of profits stemming from transactions that involve intangible assets. However, even though the DEMPE concept was included in the OECD Transfer Pricing Guidelines, its impact on the activities and profits of MNEs remains unclear. A survey conducted in 2023 revealed differing attitudes to the impact of DEMPE on MNEs’ income distribution and business operations, indicating a growing awareness of the concept but also highlighting the importance of clearer guidance on its application and integration with existing transfer pricing methodologies.

International Transfer Pricing JournalVol. 31(5)
Openalex Percentile: Top 21%
Corporate Taxation and Avoidance
0.95
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