How to Adapt to the DEMPE Concept When Using Third-Party Licensing Agreements for Transfer Pricing

15 October 2019
Dr. Yves Hervé, Philip de Homont

Managing Director Dr. Yves Hervé and Associate Director Philip de Homont have published “How to Adapt to the DEMPE Concept When Using Third-Party Licensing Agreements for Transfer Pricing” in the October/November edition of International Tax Review. It is part of the authors’ series on ways taxpayers can adapt their defense strategies to the OECD’s new DEMPE framework.

In their article, Dr. Hervé and Mr. de Homont discuss new challenges taxpayers will face in fighting complaints strengthened by the DEMPE concept of intangibles. Dr. Hervé and Mr. de Homont also suggest ways companies can preempt or counter claims by tax authorities that their local DEMPE contributions are not considered.