Application of the DEMPE Concept in the Pharmaceutical Industry

Journal
International
International Transfer Pricing Journal 2020 (Volume 27), No. 3
With the recent implementation of BEPS Action 8 and the revised chapter VI of the 2017 OECD Guidelines, a number of questions has arisen around transactions involving the use of intangible assets and especially around the substance required to claim their ownership – the so called DEMPE functions. The purpose of this article is to understand the practical application of the DEMPE concept to pharmaceutical companies active in the development, manufacturing and distribution of generic drugs.