DEMPE is designed to help both taxpayers (including MNEs) and tax authorities achieve an accurate assessment of transactions to help with the determination of appropriate transfer pricing.

The concepts introduced in BEPS actions 8-10, such as the six-step control of risk framework and development, enhancement, maintenance, protection, and exploitation (DEMPE) functions, have …

DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) is the transfer pricing economic analysis method for allocating profits from intangible assets.

Aug 30, 2024 · Learn about DEMPE functions—Development, Enhancement, Maintenance, Protection, and Exploitation of intangibles—and their role in transfer pricing compliance for multinational …

Jun 1, 2022 · The present discussion explores DEMPE and points out significant differences between the OECD Guidelines and the Treasury regulations under Sec. 482, concerning DEMPE and risk.

May 19, 2025 · DEMPE stands for Development, Enhancement, Maintenance, Protection, and Exploitation. This framework helps clarify how to allocate profits from intangible assets.

DEMPE is central to both BEPS compliance and global audit expectations. DEMPE provides multinational groups with a transparent, structured way to evaluate how intangibles create value. It …

To determine whether an entity has economic ownership of an intangible asset, the OECD Guidelines prescribe that it should be delineated whether an entity performs the so-called 'DEMPE functions’. …

These are what you need for DEMPE—and in fact, whether it’s subcon DEMPE or even active royalties—employees that are capable of performing high-value functions.

Apr 16, 2024 · Where does the confusion stem from and what’s next? Assuming that it is now clarified that SPFs and DEMPE operate on two different conceptual levels, then where is all the uncertainty …