Abstract
An integral part of the BEPS Action Plan is the Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE) concept, which is intended to ensure a fair allocation of profits stemming from transactions that involve intangible assets. However, even though the DEMPE concept was included in the OECD Transfer Pricing Guidelines, its impact on the activities and profits of MNEs remains unclear. A survey conducted in 2023 revealed differing attitudes to the impact of DEMPE on MNEs’ income distribution and business operations, indicating a growing awareness of the concept but also highlighting the importance of clearer guidance on its application and integration with existing transfer pricing methodologies.
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