Recommendations to OECD on Intangibles Transfer Pricing (Organisation for Economic Co-Operation and Development‪)‬

September 14, 2010 On September 14, 2010, TEI submitted the following recommendations to the Organisation for Economic Co-operation and Development on a consultation relating to the Transfer Pricing Aspects of Intangibles. TEI's comments were prepared under the aegis of its European Direct Tax Committee whose chair is Anna M. L. Theeuwes of Shell International Exploration and Development B.V. Contributing substantially to the development of TEI's comments were Alain Berlier of Givaudan Flavors Corporation; Johann H. Muller of AP Moller-Maersk; and Peter H. Taylor of Dupont du Nemours International, S.A. Also contributing to the submission were Vincent Alicandri of Hydro Networks, Inc.; Dorothy C. Chao of Baxter International, Inc.; Nick Hasenoehrl of Haemonetics Corporation; Robert B. Huey; Alexander Kolbl of General Dynamics Corporation; Jocelyn P. Krabbenschmidt of Amazon.com, Inc.; Janice L. Lucchesi of Akzo-Nobel, Inc.; Paul Magrath of AstraZeneca Canada Inc.; Paul V. Morton of Reed Elsevier Group, PLC; Karina O of TELUS Corporation; and Alice A. Smith of Eaton Corporation. Jeffery P. Rasmussen, legal staff liaison to TEI's European Direct Tax Committee, coordinated the preparation of the Institute's comments.