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.
Drug pricing rules and tariffs reshape transfer pricing for IP
In the article “Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP,” published in Bloomberg Tax, CRA’s Transfer Pricing experts Robin Hart and ...