The DEMPE Concept and Intangibles

preview-18
  • The DEMPE Concept and Intangibles Book Detail

  • Author : Karol Dziwinski
  • Release Date : 2022-06-06
  • Publisher : Kluwer Law International B.V.
  • Genre : Law
  • Pages : 243
  • ISBN 13 : 9403540508
  • File Size : 69,69 MB

The DEMPE Concept and Intangibles by Karol Dziwinski PDF Summary

Book Description: Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.

Disclaimer: www.yourbookbest.com does not own The DEMPE Concept and Intangibles books pdf, neither created or scanned. We just provide the link that is already available on the internet, public domain and in Google Drive. If any way it violates the law or has any issues, then kindly mail us via contact us page to request the removal of the link.

The DEMPE Concept and Intangibles

The DEMPE Concept and Intangibles

File Size : 93,93 MB
Total View : 3454 Views
DOWNLOAD

Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be share

The DEMPE Concept and Intangibles

The DEMPE Concept and Intangibles

File Size : 25,25 MB
Total View : 9296 Views
DOWNLOAD

Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be share

Ten Questions on the OECD's DEMPE Concept

Ten Questions on the OECD's DEMPE Concept

File Size : 94,94 MB
Total View : 3358 Views
DOWNLOAD

This article explores the DEMPE concept introduced by the OECD - "development, enhancement, maintenance, protection and exploitation" of intangibles - and its p

Transfer Pricing and Intangibles

Transfer Pricing and Intangibles

File Size : 90,90 MB
Total View : 3635 Views
DOWNLOAD

Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multi