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

In this article, the authors examine the Dutch tax treatment of intangible assets, with a particular focus on the DEMPE concept. It discusses the applicable legislation, administrative guidance and practical insights derived from tax audits and advance pricing agreements, as well as the current absence of case law explicitly addressing DEMPE in the Netherlands.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, Germany, Ireland, Italy, Korea, Luxembourg, Spain and the United States.