Managing Director Dr. Yves Hervé and Associate Director Philip de Homont have published “Sustaining Contract R&D Service Solutions in a Post-BEPS DEMPE Context” in the December edition of International Tax Review. It is part of the authors’ series on how taxpayers can adapt their defense strategies to the OECD’s new DEMPE framework.

In the article, Dr. Hervé and Mr. de Homont explain how and under which circumstances cost-plus solutions for contract R&D arrangements can be sustained in a post-BEPS age. In addition, they develop and apply a best-practice solution to analyze group-specific internal R&D processes.