Contract analysis

1. Scope of IDR No. 18 IDR No. 18, as issued on October 14, 2022, requested the production of all third-party distribution agreements, distribution partner arrangements, and related commercial agreements executed by or on behalf of PBI for territories outside the Americas during the period January 1, 2017 through December 31, 2020. For purposes of this request, and as defined in IDR No. 18 itself, the term "Americas"

2. Description of Documents Produced 2.1 Overview of PBI's Distribution Network To provide context for the documents produced herewith, we briefly describe PBI's role within the Penterra Pharmaceuticals group and the scope of its distribution operations. PBI serves as the principal entity for the commercialization of PPC pharmaceutical products outside the Americas. In this capacity, PBI manages distribution arrangem

3. Relevance to PBI's Economic Substance and Independent Decision-Making PPC submits that the documents produced in response to IDR No. 18 are directly relevant to the examination team's evaluation of PBI's economic substance and functional profile for purposes of the transfer pricing analysis under Section 482 of the Internal Revenue Code and the regulations thereunder. The produced documents demonstrate that PBI in

4. Relationship to PPC's Transfer Pricing Positions The documents produced in response to IDR No. 18 are directly relevant to PPC's transfer pricing positions for the tax years under examination and should be considered in conjunction with the contemporaneous transfer pricing documentation previously produced in response to IDR No. 4. PPC briefly summarizes the relevant intercompany arrangements below to provide cont

5. Reservation of Rights and Privilege PPC reserves all rights, claims, and defenses with respect to any documents not produced in response to IDR No. 18 on the grounds of attorney-client privilege, the work-product doctrine, or any other applicable privilege or protection. To the extent any documents responsive to IDR No. 18 have been withheld on the basis of privilege, such documents are identified and described on

6. Contact Information and Availability We are available to discuss the documents produced in response to IDR No. 18 and to provide any additional information that the examination team may require in connection with its review. We are committed to facilitating the efficient and orderly progression of this examination and welcome the opportunity to address any questions or concerns. For matters relating to this produc

1. Documents Responsive to IDR No. 18 (Bates Nos. PPC-IDR18-000001 through PPC-IDR18-003842)

2. Index of Produced Documents, including Bates number ranges, document descriptions, applicable product line(s), territory/market, date of agreement, and counterparty identification Reference: Master Document Production Index (maintained separately and updated to include IDR No. 18 productions) Tax Year | PBI Cost-Sharing Percentage 2017 | 38.2% 2018 | 39.5% 2019 | 41.1% 2020 | 42.7%