DEMPE v. Contractual agreements in transfer pricing of IP after BEPS

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  • Опубликовано: 6 сен 2024
  • In this webinar, Michael McDonald (EY, US) and Dr. Marta Pankiv (Tricentis, Austria) discuss the objectives, application, and (mis)interpretation of the DEMPE framework for the analysis of group transactions involving intangibles.
    Marta and Michael clarify the impact of the post-BEPS guidance on the so-called DEMPE concept on the relevant of the contractual agreements between the parties in transactions involving IP assets. They also answer the practical questions from the audience.
    The webinar is moderated by Dr. Svitlana Buriak and Rutger Hafkenscheid.
    About the speakers:
    Michael McDonald is an executive director in the national tax department at Ernst & Young. Before joining Ernst & Young, Michael McDonald was a financial economist in the Business and International Tax Division of the U.S. Treasury’s Office of Tax Analysis. In that role, Michael was a U.S. delegate at Working Party 6 of the OECD’s Committee on Fiscal Affairs, as well as Co-Chair of WP6 for the BEPS work on transfer pricing (Action Items 8-10).
    Dr. Marta Pankiv is a senior director, head of group tax and transfer pricing, at a multinational tech company, with nearly two decades of international tax experience including in leadership roles in-house and at PwC. Marta is an author, and a guest lecturer for executive transfer pricing program in Switzerland.

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