Intangibles are gaining more and more importance in the global value chain of multinational enterprises. In light of related developments pursuant to the BEPS Project, this article examines some challenging fields of the transfer pricing aspects of intangibles, i.e. identifying the ownership and assessing contributions to intangibles, which particularly includes the DEMPE concept. Moreover, the article outlines considerations and challenges in view of the practical application of the RACI model in a value chain or value contribution analysis, or in other transfer pricing documentation elements, and argues that the model should be applied with prudence in business practice.