DEMPE Across the Globe

In 2015, the Organization for Economic Cooperation and Development (OECD) reached an agreement on revised guidance for transfer pricing known as Base Erosion and Profit-Shifting (“BEPS”) actions 8-10. These actions transformed how tax authorities worldwide handle transfer pricing. The concepts introduced in BEPS actions 8-10, such as the six-step control of risk framework and development, enhancement, maintenance, protection, and exploitation (DEMPE) functions, have become fundamental in transfer pricing.

For businesses designing and implementing their transfer pricing policies, it is important to understand the specific areas of focus for each tax authority.

Learn more about how tax authorities are applying the control of risk and DEMPE frameworks by reading our article series.