The DEMPE Concept and Its role in Domestic Transfer Pricing Practice. A Survey of Country Reports

This report examines the OECD transfer pricing guidance on intangibles with reference to the DEMPE framework (Development, Enhancement, Maintenance, Protection and Exploitation) as set out in the OECD Guidelines. The report further includes the analysis of the interaction between the DEMPE framework and the domestic legislations and practices of Belgium, France, Germany, Ireland, Italy, Korea, Luxembourg, the Netherlands, Spain and the United States.