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Intercompany Royalties and Profit Splits: DEMPE, GILTI, and FDII (54:19)
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.
See how our transfer pricing solutions and services can help you lower compliance costs, mitigate tax risk, and achieve better results.Request a demo
Intelligent Transfer Pricing Technology to Manage BEPS
Vast changes to transfer pricing documentation have arrived. Are you prepared?
c a new era of transfer pricing documentation. A proactive response to country-by-country reporting, master file, and local file requirements will enable you to minimize risk and maintain your reputation.Learn more
2017 Global BEPS Survey Report
Our 2017 Global BEPS Survey Report on the results provides a closer look at the fundamental changes BEPS has brought to tax reporting for organizations worldwide. It also reveals how the world’s multinational enterprises are managing the challenges of BEPS with the help of new strategies, operational changes and technologies.Learn more