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2022 72nd Midyear Conference

T03 - It's All About Substance – Revisiting DEMPE and Related Substance Requirements in a Pillar Two/BBBA World

Mar 22, 2022 9:45am ‐ Mar 22, 2022 10:45am


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.

Learning Objectives:
  • 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.




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