The Organization for Economic Co-operation and Development (OECD) discussion draft BEPS Action 8 Implementation Guidance on Hard-to-Value Intangibles (HTVI) “provides guidance on the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.” The OECD has published the comments it received from the Big Four, Duff & Phelps, BDO, RSM, ktMINE, and others. A number of commenters suggest providing more comprehensive examples and not confining the examples to the pharmaceutical industry, as the draft does. The comment letter from ktMINE, which maintains a royalty rate database, focused on the availability of timely data and its ability to limit “information asymmetry” between taxpayers and tax administrations.