This session will address the current state of the OECD's so called "DEMPE" substance requirements for attributing income from intellectual property to a company's operations in a particular jurisdiction. Discussion will include how to approach DEMPE in light of the OECD Pillar 2 and potential U.S. tax changes that have been recently proposed.
Understand the basic requirements of the OECD's DEMPE rules.
Assess how the DEMPE rules may interact with OECD Pillar 2 and proposed U.S. tax changes
Determine how DEMPE, Pillar 2 and potential U.S. tax changes apply, or would apply, to their company's tax operations.