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The DEMPE framework provides a structured approach to identifying which entities within an MNE group contribute significantly to the creation, enhancement, maintenance, protection, and exploitation of intangibles. By delineating these functions and attributing them to specific entities, DEMPE facilitates a more accurate allocation of profits in accordance with the economic substance of each entity’s contributions.

By comparing the net profit margin of a tested party to those of comparable independent companies, TNMM provides a solid framework for validating the pricing of intercompany transactions. Global listed companies, with their readily available and reliable financial data, serve as a valuable source for identifying comparables in TNMM benchmarking analysis.

In today’s globalized economy, multinational enterprises (MNEs) rely heavily on intellectual property (IP) to maintain competitive advantages, drive innovation, and generate substantial revenue. IP assets, including patents, trademarks, copyrights, and trade secrets, are often at the core of an MNE’s business strategy. However, the unique and intangible nature of IP introduces significant complexities in Transfer Pricing.

Today we are experiencing significant and compelling shifts in global tax regulations and enforcement methods, alongside increasing enterprise-wide transformations. As various parts of an organization embrace new technologies, a multinational corporation’s tax department will be required to go beyond traditional practices and transform its tax operating model to deliver greater value to the business.

In an increasingly interconnected global economy, multinational enterprises (MNEs) face complex challenges in aligning their tax strategies with international regulatory frameworks. The OECD’s BEPS (Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting) initiative has introduced significant reforms to ensure fairer tax competition and transparency. Central to these reforms are Pillar One and Pillar Two, which seek to address issues of profit allocation and global minimum taxation, respectively.

The TP Minds International 2024 was a tremendous event, gathering Transfer Pricing experts from all over the World to share insights on the evolving international tax environment. Hosted at the Novotel London West on June 18-19, 2024, the event featured a full schedule of sessions, panel discussions, and networking opportunities. It serves as a key event for Transfer Pricing professionals and tax leaders, providing an excellent platform to discuss and exchange insights on the international tax landscape. The RoyaltyRange team was delighted to reconnect with friends, colleagues, and partners, and to forge new connections.

RoyaltyRange is a proud sponsor of the 28th General Assembly of IOTA (The Intra-European Organisation of Tax Administrations) in Budapest, Hungary. The main theme: “Using Data Science to Build Capacity and Enhance Capabilities in Tax Administrations”. It is a significant event in the realm of tax administration. Hosted by the National Tax and Customs Administration of Hungary (NTCA), the assembly was presided over by Mr. Ferenc Vágujhelyi, President of IOTA for the 2023/2024 term.

Transfer Pricing is important factor across various industries and economic sectors, particularly for those involved in cross-border transactions and intercompany dealings. One notable sector where Transfer Pricing is especially significant is the manufacturing industry. Let’s explore deeper this specific industry, try to understand its complexities and the role of Transfer Pricing.

Happy to announce that RoyaltyRange is sponsoring the 28th General Assembly of IOTA (Intra-European Organisation of Tax Administrations). The event takes place in Budapest Marriot Hotel on 19 – 20 June 2024.

Public listed companies need TNMM benchmarking studies for several critical reasons related to regulatory compliance, financial integrity, and strategic business management.