https://resources.comp-press.com/tags/ip--dempe/Recent content in IP & DEMPE on CompPress | Transfer Pricing ResourcesHugoen-usTue, 10 Mar 2026 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-exit-taxation-ip-transfer/Tue, 10 Mar 2026 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-exit-taxation-ip-transfer/<div class="art-series"><p><strong>Related reading on the Comp-Press resources page</strong></p> <ul> <li><strong>DEMPE in Practice</strong>: identifying who is entitled to intangible returns, which sets the baseline a restructuring changes.</li> <li><strong>IP Migration: A Step-by-Step Guide</strong>: the operational walkthrough for executing a move of intangibles, where this analysis supplies the exit-charge step.</li> <li><strong>Royalty Benchmarking with the CUT Method</strong>: pricing a continuing license where an intangible is transferred and licensed back.</li> </ul> </div><h2 class="art-sec" id="1-exit-taxation-is-a-transfer-pricing-problem"><span class="art-sec-num" aria-hidden="true">01</span><span class="art-sec-t">Exit Taxation Is a Transfer Pricing Problem</span> </h2><p>A business restructuring is the cross-border reorganization of the commercial or financial relations between associated enterprises, including the termination or substantial renegotiation of existing arrangements. The governing framework is Chapter IX of the OECD Guidelines, and its starting premise is that the arm&rsquo;s-length principle applies to a restructuring in the same way it applies to any controlled transaction.</p>https://resources.comp-press.com/articles/transfer-pricing-dempe-in-practice/Tue, 17 Feb 2026 00:00:00 +0000https://resources.comp-press.com/articles/transfer-pricing-dempe-in-practice/<div class="art-series"><p><strong>Related reading on the Comp-Press resources page</strong></p> <ul> <li><strong>Exit Taxation and IP Transfer</strong>: what happens when functions, and therefore entitlement, move across borders within a group.</li> <li><strong>IP Migration: A Step-by-Step Guide</strong>: how to plan and execute a move of intangibles within a group, where the DEMPE analysis sets the baseline.</li> <li><strong>Royalty Benchmarking with the CUT Method</strong>: pricing the license once entitlement and the transaction are delineated.</li> </ul> </div><h2 class="art-sec" id="1-why-the-framework-exists"><span class="art-sec-num" aria-hidden="true">01</span><span class="art-sec-t">Why the Framework Exists</span> </h2><p>The modern approach to intangibles grew out of a specific concern. Multinational groups were able to assign legal ownership of valuable intangibles to group members in low-tax jurisdictions, members that often carried out little economic activity, and then route a large share of the group&rsquo;s intangible-related profit to those owners on the strength of title alone. The contractual paperwork allocated functions, assets, and risks in a way that did not match where the real economic activity took place.</p>