DEMPE is not complicated – It is simply IP substance

For those who cared then, there was a lot of panic when the first drafts of the OECD BEPS (base erosion and profit shifting) action items were circulated.

The Action Plan had implications that were not limited to taxation and economic development. In later drafts it became more evident that intellectual property would receive extensive attention. Action Items 8 to 10 address the aspects of intangible assets with respect to preventing base erosion and profit shifting.

Why the European Commission Apple decision IS significant for policy and behaviour

In August 2016, the European Commission issued a final decision in its investigation into the way Apple paid tax in Ireland. The sheer scale of the decision was dramatic and made headlines around the world. In the aftermath, analysts said that the ruling was limited to the specific facts around the Apple case and would not apply to other international companies in Ireland.

This may be true, but the reality is that this case is a significant wake-up call. It is an indication of a much larger issue.