FR EA

Contract analysis

Clause-by-clause risk read on any document of the firm. Pick a contract, or open any document from a matter.

Contract analysis / idr-10-response.docx
idr-10-response.docx
1018-00009 · 5 clauses
High · 1 Medium · 1 Standard · 0
1. Description of Responsive Documents Medium
⚑ Liability cap to check against exposure
1. Description of Responsive Documents 1.1 Contract Manufacturing Agreement In response to IDR No. 10, PPC is producing the Contract Manufacturing Agreement (the "CMA") entered into between Penterra Biopharma International DAC ("PBI"), acting in its capacity as principal, and Penterra Manufacturing Ireland Ltd. ("PMI"), acting in its capacity as contract manufacturer. The CMA governs the intercompany manufacturing re
2. Document Production
2. Document Production 2.1 Bates-Numbered Documents Produced The following documents are enclosed with this letter and have been Bates-numbered for reference in accordance with the Master Document Production Index being maintained in connection with this examination: (a) The original Contract Manufacturing Agreement between Penterra Biopharma International DAC and Penterra Manufacturing Ireland Ltd., dated effective
3. Transfer Pricing Methodology Context High
⚑ Penalty / liquidated damages
3. Transfer Pricing Methodology Context To assist the examination team in evaluating the CMA in the context of PPC's overall transfer pricing framework, we provide the following brief contextual information regarding the transfer pricing methodology applicable to the intercompany manufacturing arrangement between PBI and PMI. The cost-plus eight percent (8%) markup applied to PMI's manufacturing services under the CM
4. Privilege Reservation
4. Privilege Reservation PPC has produced all non-privileged documents responsive to IDR No. 10 as described in this letter. PPC expressly reserves all rights and protections afforded under the attorney-client privilege, the work-product doctrine, and any other applicable privilege, immunity, or protection recognized under federal or state law. To the extent that any documents responsive to any outstanding IDR have b
5. Continuing Cooperation
5. Continuing Cooperation PPC remains committed to cooperating fully and in good faith with the Service's examination of the taxable years 2017 through 2020. PPC and its representatives at Calderwood & Harkness LLP will continue to respond to information document requests in a timely manner and to make appropriate personnel available for interviews and factual discussions as requested by the examination team. Should