Supporting a $175B biopharmaceutical company in an IRS tax dispute
Case study
Keystone experts help global biotech company in transfer pricing dispute.
Keystone experts help global biotech company in transfer pricing dispute.
A multinational biopharmaceutical company needed to defend a $10+ billion transfer pricing dispute brought by the IRS. The government challenged the structure of the company’s intercompany transactions between the company’s U.S. and international entities. The lawsuit stated that the biotech leader improperly allocated too much value to manufacturing operations abroad and not enough to the high-value activities conducted in the U.S. – namely R&D, IP development, regulatory strategy, and commercialization.
Keystone assembled a team of 10 leading experts from industry and academia to evaluate the key value drivers across the pharmaceutical supply chain - from R&D to the manufacturing, licensing, IP, and commercialization of biologics. The team’s analyses described the scientific foundations of biologics manufacturing, detailed the processes involved in commercializing a drug, and assessed arm’s-length terms for IP licensing and outsourcing.
To learn more about this case or Keystone’s expertise in Healthcare and Life Sciences litigation and strategy, contact science@keystone.com.