ONESOURCE

Intercompany Royalties and Profit Splits: DEMPE, GILTI, and FDII

Intercompany Royalties and Profit Splits: DEMPE, GILTI, and FDII

The OECD’s BEPS Action Plan introduced us to the concept of DEMPE as a new way of determining appropriate compensation for intangible development activities. Despite the OECD’s best efforts, individual countries may or may not implement these new concepts as part of their tax reform efforts.

We’ll walk through recent litigations involving intercompany royalties and profits splits, and explore the new scenarios presented by the combination of legal precedent, BEPS Action Plan, and U.S. tax reform.

Watch The Webinar Today

Fill out the form to download the video.


By submitting this form you are acknowledging that you have read and agree to our:

Privacy Policy