CRA provided economic analysis to a US-based biopharmaceutical company under audit by the French tax authority regarding the outbound license of novel IP from the jurisdiction. We worked in conjunction with the client’s US and European tax counsel. Rebel Curd and Robin Hart performed an internal and external CUP analysis to support an arm’s length schedule of upfront, regulatory, and sale milestone payments, and tiered royalty rates. The tax authority accepted the licensing framework as developed by CRA.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...