DEMPE Across the Globe
A review of global applications of the control of risk framework
Is your operational reality aligned with your transfer pricing policies?
Legal ownership of intellectual property is no longer enough to support your transfer pricing positions. Since the Organization for Economic Cooperation and Development (OECD) revolutionized global tax standards with BEPS Actions 8–10, tax authorities worldwide have strictly prioritized operational substance over legal form.
At the center of this scrutiny is the DEMPE framework (Development, Enhancement, Maintenance, Protection, and Exploitation) alongside the six-step control of risk analysis. Today, these are not just compliance guidelines, they are the fundamental benchmarks used by tax authorities to determine who actually earns intangible-related profits and where those profits should be taxed.
As global jurisdictions aggressively audit intangible transactions, understanding how local tax authorities interpret and apply these standards is critical to mitigating significant audit risks and double taxation.
Explore our comprehensive article series to learn how tax authorities across the globe are applying DEMPE and control of risk frameworks, and what it means for your business.
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks:
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