Contract analysis

1. Description of IDR No. 30 Request IDR No. 30, as received from Revenue Agent Dunleavy on February 17, 2023, requested the following categories of documents and information in connection with the examination of PPC's federal income tax returns for the tax years ended December 31, 2017, December 31, 2018, December 31, 2019, and December 31, 2020: (a) All documentation supporting PBI's claims under Ireland's Knowledg

2. Overview of PBI and the Knowledge Development box Regime To provide context for the documents produced herein, this Section 2 sets forth background information regarding PBI, the Irish Knowledge Development box regime, and PBI's Irish tax advisors. 2.1 Background on Penterra Biopharma International DAC Penterra Biopharma International DAC ("PBI") is a Designated Activity Company organized under the laws of Ireland

3. Documents Produced in Response to IDR No. 30 Set forth below is a description of the documents produced concurrently with this letter in response to IDR No. 30. The documents are organized by tab and are identified by Bates number range. All documents are produced in their original language (English or, where applicable, Irish statutory form); where documents were originally prepared in Irish statutory format, the

4. Explanatory Notes 4.1 Relationship of KDB Claims to Transfer Pricing PPC provides the following explanatory notes to assist the examination team in understanding the relationship between PBI's KDB claims and the transfer pricing issues under examination. PBI's KDB claims are a function of Irish domestic tax law — specifically, Part 29A of the Taxes Consolidation Act 1997 — and relate to PBI's treatment of qualifyi

5. Privilege Reservation PPC and PBI expressly reserve all claims of attorney-client privilege, attorney work-product protection, tax practitioner privilege under Section 7525 of the Internal Revenue Code, and any other applicable privilege or protection with respect to documents that have been withheld from this production. The documents withheld on grounds of privilege have been identified and described on the priv

6. Reservation of Rights PPC's production of documents in response to IDR No. 30 does not constitute a waiver of any objection to the scope, relevance, burden, or admissibility of the documents or categories of documents requested in IDR No. 30 or in any other IDR issued in connection with this examination. PPC reserves all rights to object to the use of any document produced herein in any administrative, judicial, o

7. Contact Information and Availability Should you have any questions regarding this response or the documents produced herein, please direct your inquiries to the following C&H personnel: Primary Contact for IDR Responses: Garrett Simmons, Lead Associate Calderwood & Harkness LLP 1735 Market Street, Suite 3100 Philadelphia, PA 19103 Telephone: (215) 764-3247 Email: gsimmons@calderwoodharkness.com Responsible Partner