Michael Durst notes that OECD Working Party No. 6 has corrected a widespread notion on intangibles transfer pricing that has "always has been flatly incorrect."

In an earlier article (see post below), Michael Durst suggests that the recent OECD discussion draft on transfer pricing for intangibles performs a "valuable service" by correcting "the apparently widespread misapprehension" that bearing the financial costs of IP development entitles an affiliate to the profits of the IP's exploitation.

He also suggests that "the best indicator of [the] arm’s-length division of income [between those managing and implementing intangibles creation] normally will be the relative values that the multinational group itself places on the managers and on the implementers — that is, the relative values of their compensation."

Neal Armstrong.  Summary of Michael C. Durst, "The OECD Discussion Draft on Transfer Pricing for Intangibles," Tax Notes International, 30 July 2012, p. 447 under Treaties - Art. 9.