Contract analysis

I. Introduction and Authorization Calderwood & Harkness LLP represents Penterra Pharmaceuticals Corp. ("PPC" or the "Company") in connection with the examination of PPC's federal income tax returns (Forms 1120) for tax years ending December 31, 2017, December 31, 2018, December 31, 2019, and December 31, 2020 (collectively, the "Examination Years") by the Internal Revenue Service ("IRS"), Large Business & Internation

II. Scope of IDR No. 11 As we understand the request, IDR No. 11 seeks net sales data for PPC's three principal commercial products — Veritaxol, Imvara, and Cerulon — segmented by product and by geographic territory, specifically: (i) Americas net sales and (ii) non-Americas net sales, for each of the four Examination Years (fiscal years 2017, 2018, 2019, and 2020). The Examination Team has further requested that the

III. Description of Responsive Documents and Data In response to IDR No. 11, PPC encloses the following materials: Attachment A — Product Revenue Schedule. Enclosed as Attachment A is a detailed revenue schedule providing product-level net sales data by territory (Americas and Non-Americas) for each of PPC's three principal products — Veritaxol, Imvara, and Cerulon — for each of the fiscal years 2017, 2018, 2019, and

IV. Summary of Product Revenue Data A. Overview of PPC's Principal Products PPC is a global biopharmaceutical company engaged in the research, development, manufacture, and commercialization of innovative therapies across several therapeutic areas. PPC's product portfolio during the Examination Years was anchored by three principal commercial products, each of which is described briefly below: Veritaxol. Veritaxol is

V. Relevance to Transfer Pricing Arrangements Without waiving any applicable privilege, including attorney-client privilege and work-product protection, and without making any admissions with respect to the appropriateness of PPC's transfer pricing positions or methodologies, PPC notes that the product revenue data by territory produced in response to IDR No. 11 is relevant to the intercompany transfer pricing arrang

VI. Privilege Reservation PPC produces the documents and data enclosed with this letter solely in response to the specific requests set forth in IDR No. 11 and without waiver of any applicable privilege, including the attorney-client privilege, the work-product doctrine, and any other applicable protection under federal, state, or foreign law. Any documents responsive to IDR No. 11 that have been withheld from produc

VII. Document Production List The following attachments are enclosed with this letter and are produced in response to IDR No. 11:

1. Attachment A: Product Revenue Schedule — Veritaxol, Imvara, and Cerulon, Net Sales by Territory (Americas / Non-Americas), Fiscal Years 2017–2020, including legacy compound net sales and royalty computation data.

2. Attachment B: Supporting Excerpts from PPC Internal Management Revenue Reports (Fiscal Years 2017–2020), including reconciliation to PPC's SEC Form 10-K filings and PBI's Irish statutory financial statements as audited by Crestfield & Associates LLP.

VIII. Offer of Further Cooperation PPC remains fully committed to cooperating with the Examination Team and is willing to provide additional data, documents, or clarification as may be reasonably requested by Revenue Agent Dunleavy or other members of the Examination Team in connection with IDR No. 11 or any related information requests. Should the Examination Team require access to underlying transactional data (e.g