Smjernice OECD-a o transfernim cijenama iz 1995., 2010. i 2017., točke 7.9. i 7.10.
Såsom de angivit i denna skrivelse, ”[…] it is highlyhighly unlikely that Lux SCS would have been able to find an independent entity capable or willing enter into a licensing agreement if doing so entailed that the business risk would be supported by that independent entity.