Extract to table

This declining trajectory is a hallmark of mature pharmaceutical IP and is a factor that must be considered in selecting comparable royalty rates

482-7, a controlled participant in a qualified cost-sharing arrangement must exercise control over the development and exploitation of the covered intangibles

The OECD guidance provides that an entity claiming entitlement to IP-related returns must perform the DEMPE functions that generate those returns, or must control and bear the risk associated with those functions

Accordingly, PPC must address the PCT valuation to prevent it from being used as a lever to increase the proposed CSA adjustments

Any settlement computation must properly account for all correlative adjustments between the CSA and the royalty, and any other correlative effects across the intercompany transactions