DEMPE Analysis for CUP Studies

24 August 2018
Yves Hervé and Philip de Homont

NERA Managing Director Yves Hervé and Associate Director Philip de Homont published the article “DEMPE Analysis for CUP Studies” in International Tax Review. The authors describe the method developed by NERA to address ambiguities in the development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE) concept developed by OECD and in the beginning stages of global use by tax authorities. The authors successfully applied their technique in defense of a CUP analysis for a trademark license agreement.

For a more detailed description of the NERA procedure for DEMPE analysis, read “DEMPE Analysis for CUP Studies” here.