A KPMG report provides a practical guide summarizing several important recent developments in the transfer pricing world.
DEMPE (development, enhancement, maintenance, protection, and exploitation) is a relatively new concept that emerged from the 2015 base erosion and profit shifting (BEPS) project, and refers to the “substance” an entity must have to be entitled to returns from assuming risk or owning intangibles. An entity is entitled to extraordinary returns from economically significant risks and intangibles only if it performs DEMPE functions.
This KPMG report:
Read a 2020 report* [PDF 262 KB] prepared by KPMG Global Transfer Pricing Services professionals in the United States
*This report originally appeared in Tax Notes International (27 January 2020) and is provided with permission of the publisher.
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