DEMPE

DEMPE, OECD, Transfer Pricing

(Agoda)/ /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…

Advance pricing agreement, Anti-tax avoidance, BEPS, Corporate income tax, DEMPE, Intangibles, International Tax Law, IP, MAPs and APAs, MNE Profits, OECD, Tax Avoidance, Transfer Pricing, United Kingdom

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation cannot be underestimated. The recent decision of the UK Upper Tribunal in in Refinitiv Ltd and others v HM Revenue &…

Belgium, DEMPE, Intangibles, Transfer Pricing

, (PWC)/ /1 Comment

Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium Raphaël Devroye – Transfer Pricing Manager at PwC Belgium In a recent judgement[1], the Belgian Court of Appeal of Ghent ruled in favour of the taxpayer as regards a transfer pricing case in relation to intangibles. Even though the case is complex…