Buch, Englisch, 288 Seiten
Definition, Practical Approach and Analysis in the Context of Licence Model
Buch, Englisch, 288 Seiten
ISBN: 978-94-035-4045-0
Verlag: Kluwer Law International
Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following:
- role of the DEMPE concept within the framework of international tax law and transfer pricing;
- interplay of the DEMPE concept with the arm’s length principle;
- full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences;
- modes of application of the DEMPE concept which can be directly implemented in practice; and
- additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept.
The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations.
Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.