The OECD BEPS project identified the valuation and transfer of intangible property (IP) as one method a company uses to shift profits out of high tax jurisdictions. BEPS Action Report 8-10 describes the activities which create value and control significant economic risks, thereby requiring entities performing these activities to earn an appropriate return for their contributions. BEPS Action Report 8-10 defines these activities with the acronym DEMPE. What does the acronym DEMPE mean and how do DEMPE activities create value according to the OECD Action Report 8-10? In your opinion, how should the arm’s length price for DEMPE activities be determined?