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Extract to table / irc-482-legal-analysis-memo.docx
irc-482-legal-analysis-memo.docx
Parties
Harkness LLP
Penterra Pharmaceuticals Corp
Evaluating Penterra Pharmaceuticals Corp
Altera Corp
Harborview Corp
Whitmore Valuation Group LLC
PPC's Global Corp
Penterra Manufacturing Ireland Ltd
Dates
July 20, 2022
May 16, 2022
July 1, 2012
June 2, 2022
June 20, 2022
December 31, 2020
January 1, 2018
Amounts
$312
$278
$361
$6.82
$1.47
€2.14
€1.06
$3.12
$1.34
$1.87
Obligations
482-1(d) identifies a non-exhaustive set of factors that must be considered in evaluating the comparability of controlled and uncontrolled transactions
PBI's functional profile must therefore be carefully documented
The regulations recognize that contract terms—including provisions regarding payment, duration, termination, volume, and scope of rights—can materially affect the pricing of a transaction and must be considered in the comparability analysis
The regulations further provide, however, that the contractual terms of a controlled transaction must be consistent with the economic substance of the parties' actual conduct
The pharmaceutical industry presents unique economic conditions that must be reflected in the comparability analysis
PBI's actual profitability must fall within this range to be defensible