Germany: Sustaining contract R&D service solutions in a post-BEPS DEMPE context Managing Director Yves Hervé and Associate Director Philip de Homont of NERA Economic Consulting explain how, and under which circumstances, cost-plus solutions for contract R&D arrangements can be sustained in... By Philip de Homont & Yves Hervé December 17 2019
Germany: How to adapt to the DEMPE concept when using third-party licensing agreements ... 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. By Philip de Homont & Yves Hervé October 15 2019
Germany: Approaching VCA and DEMPE analysis Yves Hervé and Philip de Homont from NERA Economic Consulting propose a practical approach to structuring DEMPE analysis. By Philip de Homont & Yves Hervé August 29 2019
Germany: Relocations of functions and adjustment payments Germany has been an early indicator of how the OECD’s rules on so-called ‘hard-to-value intangibles’ may look when implemented at the national level. By Philip de Homont & Yves Hervé July 10 2019
Germany: A practical solution for hard to value intangibles 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. By Philip de Homont & Yves Hervé May 28 2019
German transfer pricing methods in the context of digital transformations 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... By Philip de Homont & Yves Hervé March 21 2019
Germany: Digitisation trends and use of the profit split method By Philip de Homont & Yves Hervé January 28 2019
Germany: Profit-split considerations in TNMM solutions in a post-BEPS world The combined effect of the globalisation of entrepreneurial responsibilities within multinationals and the OECD's BEPS initiative puts traditional one-sided transfer pricing (TP) methods under increased pressure. By Philip de Homont & Yves Hervé December 12 2018
Germany: DEMPE analysis for CUP studies In TP audits around the world, tax authorities are starting to use the development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE) concept that was recently established by the OECD. By Philip de Homont & Yves Hervé August 24 2018
