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PKF newsletter 05|2022

Implementation of the DEMPE concept for intangible assets

In this edition of our newsletter we have turned our attention to the implementation of the so-called DEMPE concept for intangible assets in the context of transfer pricing. With the introduction of Section 1(3c) of the External Tax Relations Act (Außensteuergesetz, AStG), for periods starting in 2022, the German government has, for the first time, provided a definition of the term ‘intangible assets’ as well as a guideline for determining the allocation of income derived from transferring such assets or making them available for use.


Information on our website is of general nature. Although we try to archive the utmost precision and topicality with great care, the information ought not to be used without professional advice on basis of a careful review of the circumstances in each individual case.

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