On 25-27 April 2023, IOTA had the pleasure of hosting the Case Study Workshop on “Transfer Pricing Special Issues: Intangible Asset Value Creation/Determination” in Budapest, Hungary. As the first fully face-to-face technical activity of the year, the Case Study Workshop welcomed 47 tax officials from 27 IOTA member administrations to the event.
The concept of development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE) is designed to help both taxpayers (including Multi-National Entities) and tax authorities arrive at fair arm’s length pricing for related party transactions involving intangibles. For this reason, it is very useful to share good practices, techniques, and methods used to apply and implement the DEMPE framework. The IOTA workshop brought together the latest member-country experiences, presented practical examples, and discussed challenges in assessing and determining the value of contributions to DEMPE functions
The focus of the Workshop was the presentation of a series of selected anonymised case studies from IOTA member tax administrations such as Belgium, Denmark, Ireland, Switzerland, and the United Kingdom. These have been designed to illustrate working methods used, challenges arising, and application of best practices in the approach of member tax administrations.
Each case presented during the Workshop was discussed by the participants in smaller breakout sessions in order to exchange their own views, ideas, and experiences regarding the application of DEMPE functions in the cases as well as proposing alternative potential approaches if applicable.
On the first day of the Workshop, Colin Miller, a Swedish representative (former HMRC tax official) opened the floor for discussions and gave valuable insights into the theoretical background of how transactions between related parties, concerning intangibles and the application of DEMPE functions, should be handled.
During the 3-day technical activity, the following IOTA countries brought challenging and thought-provoking case study presentations on the stage:
- Belgium: Bernard de Gottal & Laurent Portugaels;
- Denmark: Søren Beck & Kasper Bisgaard;
- Ireland: Patrick Buttimer & Richard Lombard;
- Switzerland: Nate Zahnd & Thibaut Urbain;
- United Kingdom: Paul Meagher
A special thanks goes out to the Belgian and Swiss delegations for making this Workshop sweeter with their delicious chocolates along with the Irish colleagues for their kind representative gift.
This Workshop was led by IOTA International Taxation Experts Alexandros Roukalis and Oksana Stepanenko. All the materials, presentations, photos, and video summary of the event will be made available soon for registered IOTA website users on the event’s webpage.