Giammarco Cottani, Author at Kluwer International Tax Blog

By Giammarco Cottani

Gianmarco Cottani is Head of Tax at Agoda – one of the world’s fastest-growing online travel booking platforms, part of Booking Holdings Group – where he leads the Tax function.

Previously, Giammarco worked as Director – Global Tax Policy at Netflix, where he spearheaded the tax public policy- related issues the group faces in the countries in which Netflix operates. Before that, Giammarco was a partner of the international tax law firm Ludovivi Piccone & Partners. Where he coordinated the international transfer pricing practice.

Giammarco received his degree in Law from LUISS Rome University in 2003, and LL.M in European and International Taxation from the European Tax College in 2005, and a Ph.D. in Corporate Taxation from LUISS University in 2009.

DEMPE, OECD, Transfer Pricing

Evaluation of the OECD Conceptual Framework around SPFs and DEMPE: Where do we stand today?

Giammarco Cottani (Agoda)/April 16, 2024April 17, 2024 /Leave a comment

Introduction The present contribution aims at discussing two fundamental concepts often coming into play in the analysis of transactions between associated enterprises involving intangible property: the notion of (i) significant people functions (“SPFs”)[1] and that of (ii) development, enhancement, maintenance, protection and exploitation of intangible property (“DEMPE”)[2]. Based on my practical experience, lately these two…