The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice – Report on Germany

While the transfer pricing of intangible assets has long been one of the most complex topics in transfer pricing, and is often controversially discussed with the German tax authorities, including the German competent authority, the main principles of the DEMPE approach have become legally applicable from a German perspective.This article is part of a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic transfer pricing practice. The other articles include the General Report and contributions on Belgium, France, Ireland, Italy, Korea, Luxembourg, the Netherlands, Spain and the United States.