DEMPE Functions in Practice: The International Approach and Lessons Learned over the Last Years
DEMPE Functions in Practice: The International Approach and Lessons Learned over the Last Years

Summary/Abstract: The article discusses practical experiences with the application of the DEMPE concept over the years since its official introduction in the 2017 OECD Transfer Pricing Guidelines. Starting with placing the concept in the transfer pricing realm, the article then moves on to deal with the most common issues in its practical application, which include also an analysis of the application of the concept in Cost Contribution Arrangements. Finally, the article discusses the real-life application of the DEMPE concept in the countries such as Austria, Belgium, China, Germany, and India.

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