For this session, Guy Sanschagrin will lead our focus from services to intangibles. Guy will prepare an outline of the OECD initiatives around intangibles and lead an interactive session with others to encourage interaction and discussion on this topic. Mike Gregory will bring a perspectve to weave in the theme of issue resolution as a tool to manage transfer pricing risks. Issues discussed will include transfer pricing risks associated with intangibles, identifying internal and external license agreement comparables, factors used to evaluate comparables, methods used to value intangibles, and ramifications of these methods in terms of time and resources as well governmental review.