Yves Hervé and Philip de Homont of NERA Economic Consulting show how taxpayers can adapt their defence strategies to the DEMPE concept, focusing particularly on the use of third-party agreements.
It is likely that many tax disputes will arise from the new definition of hard to value intangibles (HTVI) in the OECD's transfer pricing (TP) guidelines.
In our last article, we described the challenges that the digital transformation poses for transfer pricing (TP). In this article, we want to show how emerging business interdependencies can be translated into new TP models.
This article describes the challenges that the digital transformation of the economy poses for transfer pricing. In the next article of the series, it will show how these interdependencies can be translated into new transfer pricing models.
