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Guide on DEMPE in Transfer Pricing

DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) is the transfer pricing economic analysis method for allocating profits from intangible assets. It shifts the focus from simple legal ownership to a detailed analysis of which entities actually perform the key value-creating functions, contribute assets, and control significant risks. DEMPE ensures that returns from intangibles are rewarded to the group members that create economic value, aligning profit with substance.

The concept of DEMPE functions has revolutionized how multinational enterprises approach transfer pricing for intangible assets, fundamentally reshaping the allocation of profits derived from intellectual property across international tax jurisdictions. 1 This framework, which stands for Development, Enhancement, Maintenance, Protection, and Exploitation, emerged as a cornerstone of the OECD’s Base Erosion and Profit Shifting (BEPS) initiative, specifically targeting the artificial shifting of profits through intangible property arrangements. 2 The DEMPE analysis represents a paradigm shift from traditional legal ownership-based approaches to a substance-over-form methodology that examines the actual economic activities contributing to intangible value creation. 3

Historical Context and Evolution of DEMPE

The Pre-BEPS Landscape

Before the introduction of DEMPE functions, transfer pricing rules for intangibles primarily relied on legal ownership as the determinative factor for profit allocation. 4 This approach often resulted in situations where entities with minimal economic substance could claim significant returns from intangible assets simply by holding legal title. 5 Multinational enterprises frequently exploited these rules by creating artificial structures that separated legal ownership from the functions, assets, and risks that actually created value. 6

BEPS Actions 8-10 and the Birth of DEMPE

The OECD’s BEPS Action Plan identified intangible-related profit shifting as a significant concern, leading to the development of Actions 8-10 specifically targeting these arrangements. 7 The final reports on these actions, published in October 2015, introduced the DEMPE framework as a mechanism to ensure that profits associated with intangibles are allocated to jurisdictions where actual value creation occurs. 8 This represented a fundamental shift toward aligning transfer pricing outcomes with value creation, moving beyond the formalistic approach of previous guidance. 9

Integration into OECD Guidelines

The DEMPE framework was formally incorporated into Chapter VI of the OECD Transfer Pricing Guidelines in 2017, replacing the previous intangible ownership guidance. 10 This integration established DEMPE as the authoritative standard for analyzing intangible-related transactions between associated enterprises. 11 The framework applies to all types of intangibles, from traditional intellectual property like patents and trademarks to more complex assets such as trade secrets and marketing intangibles. 12

The Five DEMPE Functions Explained

Development Function

The Development function encompasses all activities related to the creation of new intangible assets or the initial formation of intellectual property. 13 This includes research and development activities, whether conducted internally or outsourced to third parties, as well as the strategic decisions surrounding the direction and scope of development programs. 14 Key development functions involve the design and control of research programs, direction and establishment of priorities for creative undertakings, and control over strategic decisions regarding intangible development programs. 15

The significance of development functions extends beyond mere execution of research activities to encompass the higher-level decision-making processes that guide the creation of value. 16 For pharmaceutical companies, this might include decisions about which compounds to pursue in clinical trials, while for technology companies, it could involve determining the architectural framework for new software platforms. 17

Enhancement Function

Enhancement functions relate to activities that improve, upgrade, or add value to existing intangible assets. 18 Unlike development, which creates new assets, enhancement focuses on increasing the value or extending the useful life of intangibles that already exist. 19 This can include technological improvements to existing products, expansion of trademark rights into new markets, or adaptation of existing know-how for new applications. 20

The enhancement function is particularly relevant in fast-moving industries where continuous improvement is essential for maintaining competitive advantage. 21 Software companies regularly enhance their products through updates and new features, while pharmaceutical companies may enhance existing drugs through new formulations or delivery mechanisms. 22

Maintenance Function

Maintenance functions encompass activities necessary to preserve the value and functionality of intangible assets over time. 23 This includes both routine upkeep activities and more substantive actions required to prevent depreciation or obsolescence of the intangible. 24 Maintenance activities can range from basic administrative tasks like renewing patent registrations to more complex undertakings such as ongoing quality control and performance monitoring. 25

The scope of maintenance functions varies significantly depending on the type of intangible asset involved. 26 For trademark-intensive businesses, maintenance might involve consistent brand monitoring and enforcement activities, while for technology-based intangibles, it could include regular system updates and security patches. 27

Protection Function

Protection functions involve activities designed to safeguard intangible assets from unauthorized use, infringement, or misappropriation. 28 This encompasses both legal protection measures, such as patent prosecution and trademark enforcement, and practical protection strategies, including trade secret security protocols and confidentiality agreements. 29 Important protection functions include making decisions regarding the defense and protection of intangible assets and implementing ongoing quality control measures that may affect the value of the intangible. 30

The protection function extends beyond formal legal mechanisms to include strategic decisions about how to maintain competitive advantages. 31 Companies must balance the benefits of patent protection against the disclosure requirements that come with patent applications, and they must develop comprehensive strategies for protecting trade secrets and know-how. 32

Exploitation Function

Exploitation functions encompass all activities related to the commercialization and monetization of intangible assets. 33 This includes both direct exploitation through the use of intangibles in commercial operations and indirect exploitation through licensing arrangements with third parties. 34 Exploitation activities involve manufacturing products that incorporate patented technology, marketing branded goods, or licensing intellectual property to generate royalty income. 35

The exploitation function is often where the most significant economic returns from intangible assets are realized, making it a critical component of the DEMPE analysis. 36 Successful exploitation requires not only access to the intangible asset but also the capabilities, infrastructure, and market presence necessary to extract value from it. 37

DEMPE Analysis Framework

Functions, Assets, and Risks Analysis

The DEMPE framework operates within the broader context of the functions, assets, and risks analysis that underpins all transfer pricing methodologies. 38 However, DEMPE provides specific guidance for identifying and evaluating the functions, assets, and risks that are particularly relevant to intangible asset value creation. 39 This analysis must consider not only the direct activities performed by each entity but also the control exercised over important functions and the assumption of economically significant risks. 40

The functions analysis under DEMPE requires a detailed examination of who performs each of the five DEMPE functions and who controls the strategic decisions related to each function. 41 This control element is crucial because entities that merely execute functions under the direction of others may not be entitled to the same level of compensation as those that make key strategic decisions. 42

Asset Contribution Assessment

The assets component of DEMPE analysis examines the tangible and intangible assets that contribute to the development, enhancement, maintenance, protection, and exploitation of intangibles. 43 This includes funding provided for intangible development, pre-existing intangibles used as platforms for further development, and physical assets such as research facilities and manufacturing equipment. 44 The provision of funding is often the most significant asset contribution, but entities that provide funding without performing important functions or controlling risks are typically entitled only to risk-adjusted financial returns rather than residual profits. 45

Risk Allocation and Control

Risk analysis under DEMPE focuses on identifying economically significant risks associated with intangible development and determining which entities actually control and have the financial capacity to assume those risks. 46 Key risks include development risks, technology obsolescence risks, infringement risks, product liability risks, and exploitation risks. 47 The OECD Guidelines emphasize that contractual risk allocation must be supported by actual control over risk and sufficient financial capacity to bear the consequences if risks materialize. 48

Functional Ownership vs. Legal Ownership

The Paradigm Shift

One of the most significant changes introduced by the DEMPE framework is the concept of functional ownership, which can differ substantially from legal ownership. 49 Functional ownership is determined by analyzing which entities perform the important DEMPE functions, contribute significant assets, and control economically significant risks. 50 This approach ensures that entities with legal title but minimal economic substance cannot claim disproportionate returns from intangible assets. 51

Determining Functional Ownership

The determination of functional ownership requires a comprehensive analysis of all DEMPE-related activities within a multinational group. 52 Entities that perform important functions related to multiple DEMPE categories, contribute significant assets, and control key risks are more likely to be considered functional owners entitled to residual returns. 53 Conversely, entities that serve primarily as passive funding vehicles or merely hold legal title without substance are typically entitled only to routine returns. 54

Important Functions Hierarchy

The OECD Guidelines identify certain functions as particularly important for determining functional ownership. 55 These include design and control of research and marketing programs, direction and establishment of priorities for creative undertakings, control over strategic decisions regarding intangible development programs, and management and control of budgets. 56 Entities that perform these important functions are more likely to be considered functional owners, while those that merely execute routine activities under direction from others may receive only service provider compensation. 57

Practical Application of DEMPE

Step-by-Step Analysis Process

Implementing DEMPE analysis requires a systematic approach that begins with identifying all intangibles relevant to the controlled transactions. 58 This identification must be comprehensive and specific, going beyond formal intellectual property registrations to include all assets that meet the OECD definition of intangibles for transfer pricing purposes. 59 The analysis then proceeds to map all DEMPE functions performed within the multinational group, identifying which entities perform each function and the level of control exercised. 60

Documentation and Evidence Requirements

Proper DEMPE analysis requires extensive documentation to support conclusions about functional ownership and profit allocation. 61 This documentation should include organizational charts showing reporting relationships, job descriptions for key personnel involved in DEMPE functions, board minutes and other records of strategic decision-making, and financial records demonstrating asset contributions and risk assumption. 62 Contemporary documentation is strongly preferred, as post-facto reconstruction of DEMPE arrangements may lack credibility with tax authorities. 63

Transfer Pricing Method Selection

The results of DEMPE analysis significantly influence the selection of appropriate transfer pricing methods. 64 Where a single entity performs most important DEMPE functions and is considered the functional owner, traditional one-sided methods such as the transactional net margin method may be appropriate for testing other entities’ returns. 65 However, where multiple entities make significant DEMPE contributions, profit split methods are often more suitable for reflecting the economic substance of the arrangements. 66

Challenges and Considerations

Complexity in Implementation

One of the primary challenges in applying DEMPE analysis is the complexity that arises when multiple entities within a multinational group contribute to different aspects of intangible development and exploitation. 67 This complexity is compounded by the integrated nature of many modern business operations, where functions, assets, and risks are distributed across multiple jurisdictions in ways that may not have clear third-party comparables. 68 Tax authorities and taxpayers must navigate these complexities while maintaining consistency with the arm’s length principle. 69

Timing and Valuation Issues

DEMPE analysis often involves intangibles that generate returns over extended periods, creating challenges in timing the recognition of value creation activities and the returns attributable to those activities. 70 Development activities may occur years before commercial exploitation begins, and the ultimate success or failure of intangible assets may not become apparent until long after initial investments are made. 71 This temporal disconnect between value creation and value realization complicates the application of traditional transfer pricing methods and may require sophisticated valuation techniques. 72

Hard-to-Value Intangibles

The DEMPE framework intersects with the OECD’s guidance on hard-to-value intangibles (HTVI), which applies to intangibles for which reliable comparables do not exist and future cash flows are highly uncertain. 73 For HTVI, tax authorities may apply ex-post analysis to examine whether actual outcomes are consistent with the assumptions underlying the original transfer pricing arrangements. 74 This creates additional compliance burdens and uncertainty for multinational enterprises engaged in cutting-edge research and development activities. 75

Industry-Specific Applications

Pharmaceutical and Biotechnology

The pharmaceutical industry presents unique challenges for DEMPE analysis due to the extended development timelines, high failure rates, and regulatory requirements that characterize drug development. 76 Development functions may span decades and involve multiple phases of clinical trials, each with different risk profiles and capital requirements. 77 Protection functions are particularly critical given the importance of patent exclusivity, while exploitation functions must account for regulatory approval processes and market access considerations. 78

Technology and Software

Technology companies often have highly integrated development processes where enhancement and maintenance functions are continuous and overlapping. 79 Software development follows agile methodologies that blur traditional distinctions between development and enhancement, while the rapid pace of technological change makes obsolescence risks particularly significant. 80 Protection functions often rely more on trade secret protection and first-mover advantages than on formal intellectual property rights. 81

Consumer Brands and Marketing

For companies with valuable brand intangibles, the enhancement and protection functions are often more significant than initial development. 82 Brand value is built through consistent marketing activities, quality control, and customer experience management across multiple markets. 83 Local marketing activities may contribute significantly to brand enhancement in specific markets, raising questions about how to allocate returns between global brand ownership and local market development. 84

Documentation Requirements and Best Practices

Contemporaneous Documentation

The OECD Guidelines emphasize the importance of contemporaneous documentation for intangible-related transactions, and this principle is particularly critical for DEMPE analysis. 85 Documentation should be prepared at or before the time that DEMPE functions are performed and decisions are made, rather than being reconstructed after the fact. 86 This documentation should clearly establish the decision-making processes, the entities responsible for key functions, and the rationale for profit allocation arrangements. 87

Organizational Structure Documentation

Effective DEMPE documentation must clearly map the organizational structure and reporting relationships within the multinational group. 88 This includes detailed organization charts, role descriptions for key personnel, and documentation of how strategic decisions are made and implemented across different entities. 89 The documentation should demonstrate not just formal authority but actual control and decision-making power. 90

Financial and Operational Records

Comprehensive DEMPE analysis requires detailed financial and operational records that support conclusions about asset contributions, risk assumption, and profit allocation. 91 This includes development budgets and expenditure tracking, funding arrangements and financial capacity analysis, and performance metrics and outcome measurement systems. 92 The records should demonstrate the economic substance of the arrangements and the actual contribution of each entity to value creation. 93

Future Developments and Considerations

Digital Economy Challenges

The ongoing digitalization of the global economy continues to create new challenges for DEMPE analysis. 94 Digital business models often involve automated processes, algorithm-driven decision-making, and user-generated value that don’t fit neatly within traditional DEMPE categories. 95 Tax authorities and taxpayers must adapt DEMPE principles to address these new business realities while maintaining consistency with fundamental transfer pricing principles. 96

Regulatory Coordination

As more countries adopt DEMPE-based approaches to intangible asset taxation, coordination between tax authorities becomes increasingly important to avoid double taxation and ensure consistent application of the principles. 97 The OECD’s work on tax certainty and dispute resolution mechanisms will likely continue to evolve to address DEMPE-related controversies. 98 Multilateral approaches to DEMPE implementation may become necessary to ensure effective coordination across jurisdictions. 99

The DEMPE framework represents a fundamental evolution in transfer pricing for intangible assets, moving beyond formalistic legal ownership to focus on economic substance and value creation. 100 While the framework provides a robust methodology for analyzing intangible-related transactions, its successful implementation requires careful attention to documentation, thorough analysis of functions, assets, and risks, and adaptation to industry-specific circumstances. 101 As the digital economy continues to evolve and intangible assets become even more central to business value creation, the DEMPE framework will undoubtedly continue to develop and refine its approach to ensuring that transfer pricing outcomes align with economic reality. 102

  1. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.32
  2. Dulce Miranda, Definition and Identification of Intangibles, in Intangibles in the World of Transfer Pricing, 2021, page 3
  3. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 14
  4. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.40
  5. An Overview of Transfer Pricing by IBFD, 2018, section 15.2
  6. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  7. An Overview of Transfer Pricing by IBFD, 2018, section 15.2
  8. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.4
  9. Dulce Miranda, Definition and Identification of Intangibles, in Intangibles in the World of Transfer Pricing, 2021, page 4
  10. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.34
  11. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 15
  12. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.3
  13. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.2
  14. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  15. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.56
  16. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  17. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.3
  18. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.2
  19. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  20. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.50
  21. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.6
  22. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 17
  23. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.2
  24. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  25. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.56
  26. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.3
  27. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 17
  28. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.2
  29. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  30. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.56
  31. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.2
  32. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 18
  33. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.2
  34. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, footnote 3
  35. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  36. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.7
  37. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 19
  38. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.32
  39. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  40. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 17
  41. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.34
  42. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 18
  43. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.6.1
  44. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  45. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.62
  46. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.1
  47. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 18
  48. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 1.65
  49. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 14
  50. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  51. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.32
  52. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  53. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.2
  54. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.62
  55. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 16
  56. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.56
  57. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.2
  58. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.34
  59. Dulce Miranda, Definition and Identification of Intangibles, in Intangibles in the World of Transfer Pricing, 2021, page 5
  60. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  61. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.36
  62. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 20
  63. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  64. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.2
  65. Arjuna Sky Kok, Transfer Pricing in Manufacturing, 2019, chapter on profit split method
  66. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 2.124
  67. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.33
  68. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  69. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 21
  70. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.33
  71. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.2
  72. An Overview of Transfer Pricing by IBFD, 2018, paragraph 6.189
  73. An Overview of Transfer Pricing by IBFD, 2018, paragraph 6.189
  74. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.189
  75. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 22
  76. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.3.3
  77. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 18
  78. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.2
  79. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 17
  80. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.2
  81. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.38
  82. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.7
  83. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 19
  84. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.2.4.7
  85. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.36
  86. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 20
  87. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  88. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.35
  89. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 18
  90. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.5.4
  91. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.59
  92. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.6.1
  93. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 19
  94. PWC International Transfer Pricing 2015-2016, Action 3 section
  95. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 22
  96. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  97. PWC International Transfer Pricing 2015-2016, cooperation section
  98. An Overview of Transfer Pricing by IBFD, 2018, arbitration section
  99. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
  100. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, 2022, paragraph 6.32
  101. S. Karnath, Allocation of IP for TP Purposes, in Intangibles in the World of Transfer Pricing, 2021, page 24
  102. United Nations Practical Manual on Transfer Pricing, 2021, paragraph 6.3.4.1
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