CRA was engaged by a multinational pharmaceutical firm to assist in the preparation and negotiation of a series of unilateral and bilateral Advance Pricing Agreements (APAs) covering distribution, research and development, marketing, and management support functions simultaneously across a number of jurisdictions, including U.S., U.K., Canada, Germany, France, and Spain. As a part of this project, we:
- Tested and developed various economic methodologies to establish a favorable and defensible position for the client;
- Prepared APA submission reports setting out the economic analysis used to support the client’s position in each jurisdiction;
- Anticipated and responded to a series of inquiries and data requests issued by the tax authorities;
- Reviewed the position papers prepared by the tax authorities, addressing their positions and arguments; and
- Assisted our client in preparing annual reports that demonstrated compliance with the terms and conditions of the APAs and are supporting the renewal process as the original agreements expire.