Contract analysis

1. Introduction and Purpose Calderwood & Harkness LLP ("C&H") was retained by Penterra Pharmaceuticals Corp. ("PPC") on June 2, 2022, to represent PPC in connection with a multi-year examination initiated by the Internal Revenue Service Large Business & International Division (Exam Team LB&I-NE-TP-2022-00641). The IRS examination challenges the transfer pricing methodology employed between PPC and its Irish subsidiar

2. Interview Methodology 2.1. Format and Logistics All twelve interviews were conducted in person at PBI's offices located at 4th Floor, Claremont House, Sandyford Business Park, Dublin D18 K7T4, Ireland. Each interview was scheduled for a duration of approximately 60 to 120 minutes, depending on the seniority and functional scope of the interviewee's role. In practice, several interviews with more senior personnel (

3. Interview Summaries The following sections set forth a detailed summary of each of the twelve interviews conducted. For each interviewee, the summary includes the date of the interview, the identity of the interviewer(s) and any WVG participants, the interviewee's title, tenure, background, reporting line, key responsibilities, decision-making authority, interaction with PPC U.S. personnel, contributions to DEMPE