Carel van Bylandtlaan 30 | ||
Mr. W. Bradshaw Skinner | 2596 HR The Hague | |
Senior Assistant Chief Accountant | The Netherlands | |
Divison of Corporation Finance | Tel +31 70 377 3120 | |
Mail Stop 7010 | Email Roy.Waight@shell.com | |
Securities and Exchange Commission | Internet http://www.shell.com | |
100 F Street, NE | ||
Washington, D.C. 20549-1090 |
RE: | Royal Dutch Shell plc Form 20-F for Fiscal Year Ended December 31, 2007 Filed March 17, 2008 Response Letter Submitted June 9, 2009 File No. 1-32575 SEC letter May 6, 2009 |
1. | We note your response to comment 2 of our letter dated May 6, 2009. We understand that your payments to governments of the countries in which you develop projects may include royalties, taxes and other fees, in addition to the amounts that you invest in actual development of the projects. We understand also that you may make other cash payments or payments in kind to those governments or to entities controlled by those governments, including payments for oil cargoes purchased in your trading operations. Finally, we understand that your operations may generate additional cash flow for those governments or entities controlled by those governments. In our view, you should expand your disclosure in future filings to make clear (i) the various types of cash payments or payments in kind that you make to, and additional cash flow that your operations generate for, the government of any country identified by |
the U.S. as a state sponsor of terrorism or any entity controlled by such a government, and (ii) the scope of such payments and additional cash flow, when the payments and additional cash flow, individually or in the aggregate, involve a significant dollar amount beyond amounts invested in the projects described in the filing. | ||
Please provide us with a draft of the type of disclosure you intend to provide in response to this comment. |
cc. | Meredith Cross, Director of the Division of Corporation Finance US Securities and Exchange Commission Brian Breheny, Deputy Director of the Division of Corporation Finance US Securities and Exchange Commission Cecilia D. Blye, Chief, Office of Global Security Risk US Securities and Exchange Commission Douglas Brown US Securities and Exchange Commission H. Roger Schwall, Assistant Director of Divison of Corporation Finance US Securities and Exchange Commission |
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