Bring Structure to DEMPE Analysis
Turn interviews, functional analysis and supporting evidence into a structured assessment of DEMPE contributions across entities.
The DEMPE Agent helps multinational enterprises systematically identify and evaluate who performs—and who controls—the functions associated with the Development, Enhancement, Maintenance, Protection and Exploitation of intangibles.
HOW IT WORKS
From information to a structured DEMPE analysis
Capture
Gather structured information about functions, responsibilities, decision-making and evidence from the people closest to the business.
Evaluate
Assess the significance of activities and contributions across Development, Enhancement, Maintenance, Protection and Exploitation.
Compare
Create a consistent entity-level view of DEMPE contributions that can support the broader functional and transfer pricing analysis.
A DIFFERENT APPROACH
Beyond a DEMPE questionnaire
The challenge isn't identifying DEMPE functions. It's evaluating their relative significance.
Different employees and entities may participate in the same DEMPE function—but their contributions are not necessarily equivalent.
The DEMPE Agent provides a structured methodology for assessing those contributions based on the activities performed, responsibilities exercised, decision-making and supporting evidence.
Case context
Individual assessment
Entity FAR results
DEMPE matrix
Define the IP, transaction, entities and scope
Capture employee-level activities, decision-making and evidence
View relative contributions across entities and functions
A structural view of DEMPE contributions to support your analysis
THOUGHT LEADERSHIP
Built on Published DEMPE Framework
The methodology behind the DEMPE Agent builds on the quantitative DEMPE framework developed by Ami Goldenstein and Frank Wang and published by Bloomberg Tax.
The framework addresses a practical challenge faced by multinational enterprises: how can the relative importance of DEMPE contributions be evaluated in a more structured, consistent and transparent manner?
Our approach introduces a systematic process for evaluating employee and entity contributions while preserving the facts-and-circumstances analysis and professional judgment required in transfer pricing.
The DEMPE Agent is not a formulary profit allocation tool.
It does not replace the functional analysis, risk analysis, accurate delineation of the transaction, selection of the most appropriate transfer pricing method, or professional judgment.
Instead, it provides a structured and repeatable framework for gathering evidence, evaluating relative DEMPE contributions and documenting the basis for those conclusions.