Details

With globalization, businesses must ensure that their cross-border transaction structures comply with international tax principles. DEMPE (Development, Enhancement, Maintenance, Protection & Exploitation of IP) and Permanent Establishment (PE) risks are key focus areas under BEPS and OECD frameworks.

We conduct detailed tax and functional evaluations to mitigate exposure, optimize cross-border operations, and ensure proper allocation of value among global entities.

Scope of Services

• Review of DEMPE functions and IP ownership models

• PE risk assessment for international operations

• Analysis of cross-border transactions and value creation

• Advisory on tax-efficient entity structures

• Preparation of supporting documentation

Where This Applies

• Transfer of intellectual property

• Offshore development centers

• Overseas subsidiaries or liaison offices

• Service and royalty arrangements

• Global supply chain re-alignment

Documents / Inputs Required

• Inter-company contracts & pricing details

• Operational workflow and functional charts

• Tax residency details of entities involved

Deliverables

• DEMPE and PE risk assessment report

• Recommendations for tax-efficient structures

• Compliance documentation and implementation plan