Michael C. Durst suggests that the OECD draft discussion on transfer pricing for intangibles will combat income shifting through the mere transfer of cash to purchase or develop intangibles

The former director of the IRS's advance pricing agreement program has suggested that the the OECD Discussion Draft on Transfer Pricing for Intangibles combats the fallacy that it complies with the transfer pricing rules for income to be shifted to low tax jurisdictions through "the mere transfer of cash" to the affiliates there, i.e.,  they use cash to purchase intangibles for their fair market value or contract to pay the fair market value of contract services to develop intangibles for their account.

Neal Armstrong.  Summary of Michael C. Durst, "OECD's Fight Against Income Shifting - and for Its Global Role," Tax Notes International, 3 December 2012, p. 933 under Treaties -Art. 9.