March 2018
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…
September 2017
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…
August 2017
Under the arm‘s length principle, each member of the multinational enterprise group should receive arm‘s length compensation for the functions it performs…
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…
December 2018
In order to demonstrate the way in which an MNE might go about conducting a functional analysis for transfer pricing with DEMPE in mind, an example scenario has been outlined in our DEMPE white paper.