DEMPE, PE Risk Review & Cross-Border Transactions
"Strategic evaluation of DEMPE functions, Permanent Establishment (PE) risks, and cross-border transactions for compliant global tax structures."
Service Overview
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
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Review of DEMPE functions and IP ownership models
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PE risk assessment for international operations
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Analysis of cross-border transactions and value creation
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Advisory on tax-efficient entity structures
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Preparation of supporting documentation
Where This Applies
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Transfer of intellectual property
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Offshore development centers
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Overseas subsidiaries or liaison offices
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Service and royalty arrangements
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Global supply chain re-alignment
Documents / Inputs Required
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Inter-company contracts & pricing details
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Operational workflow and functional charts
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Tax residency details of entities involved
Deliverables
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DEMPE and PE risk assessment report
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Recommendations for tax-efficient structures
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Compliance documentation and implementation plan