In this article, we explain how an allocation of returns derived by a multinational enterprise (MNE) from the intangibles it owns may be allocated among legal entities in accordance with these entities’ participation in functions performed, assets used, and risks assumed in the development, enhancement, maintenance, protection, and exploitation of intangibles, commonly referred to as the “DEMPE" activities. We also demonstrate a solution to a technically challenging aspect of DEMPE contributions: How to measure the impact of historic DEMPE contributions to a brand’s value today.
