Abstract
This study is focusing to analyze the implications of implementing the concept of function identi?cation in the intangible assets that is discussed in Action 8-10, known as DEMPE, in the Indonesia’s transfer pricing regulations. This research method is descriptive research with more priority to in-depth interview as primary data source. The result of this research is that there is relevance to apply BEPS Action Plan 8–10 in Indonesia, DEMPE concept can be applied effectively in Indonesia to overcome various problems, and its implementation only requires less signi?cant adjustment because implicitly DEMPE concept has been applied mainly as basic inspection. Implementation in Indonesia’s pricing transfer rules can create new regulations that are generally described in PMK and the details will be explained in PER by adjusting to the relevance in Indonesia that allows added “marketing” function in the DEMPE concept. This implementation is expected to be able to get closer to each stakeholder’s perspective regarding to the procedure of identifying intangible assets that emphasizes the analysis of economic ownership.
