Webcast overview
DEMPE has been a big part of the global transfer pricing landscape for just over a decade. Even though DEMPE is relevant for most taxpayers, it remains a mystery after 10 years– with numerous unknowns, a myriad of, sometimes wildly, different perspectives and increasing challenges for taxpayers to effectively manage DEMPE related risk. KPMG LLP (KPMG) is pleased to invite you to a one-hour TaxWatch Webcast that will explore the evolution of DEMPE and many of the more important (and often controversial) ways to interpret these rules and apply them in your business.
The panel will bring varied perspectives on these issues – from an OECD Senior Transfer Pricing Advisor to a law school professor to the views from within the Big 4, and will discuss topics including following:
- Where does DEMPE actually “fit” into the risk control framework and the overall determination of a transfer price?
- In situations where some form of a profit split pricing method is appropriate, what is the right way to consider DEMPE?
- What is the “appropriate remuneration” owed to non-IP owners who perform DEMPE functions?
- How do we reconcile DEMPE with real world economic value?
- Is DEMPE (and particularly the headcount-based profit split theory) accelerating a move to global formulary apportionment?
- In the context of audits, what are tax authorities getting right – and what are they getting wrong?
