Transfer Pricing for Pharmaceuticals & Life Sciences

Transfer Pricing Strategies for Pharmaceuticals & Life Sciences Sector

Transfer Pricing for Pharmaceuticals and Life Sciences demands expertise across research, manufacturing, licensing, and distribution. 

Ensure global compliance with Transfer Pricing in the Life Sciences industry.

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Leading transfer pricing firm
WHY CHOOSE US

Why Choose Us for Pharmaceuticals & Life Sciences Transfer Pricing?

We understand the complexity of the global pharma value chain — from R&D cost-sharing to IP ownership and global distribution. Our tailored Transfer Pricing strategies help mitigate risks, align profit with substance, and ensure defensible documentation in every jurisdiction.

01

Transfer Pricing Strategy

Transfer Pricing Strategy for R&D and manufacturing entities.
02

Benchmarking Analysis

Benchmarking and economic analysis of intangibles and royalties.
03

Documentation Support

Documentation support aligned with OECD Transfer Pricing Guidelines.
04

Audit Risk Mitigation

Risk assessment and dispute resolution assistance.
Pharmaceuticals & Life Sciences
Industries We Support

Customized Transfer Pricing Solutions for Life Sciences Businesses Worldwide

Pharmaceuticals & Life Sciences

Major Transfer Pricing Issues in Pharmaceuticals & Life Sciences

The Life Sciences sector faces intense scrutiny due to the global mobility of intangibles and R&D cost structures. Our experience helps clients manage:

Pharma companies rely heavily on intellectual property — patents, trademarks, and proprietary formulas.
Accurately valuing these intangibles and establishing royalty rates under OECD Transfer Pricing Guidelines is crucial to avoid disputes and double taxation.
Global R&D collaborations require clear cost allocation between related entities.
Properly structured cost-sharing agreements ensure compliance while recognizing the contributions of each participant in innovation and product development.
Determining arm’s length royalty rates for licensing proprietary drugs or manufacturing processes is a key Transfer Pricing challenge.
Benchmarking analyses help justify these intercompany payments and withstand tax authority scrutiny.
Many pharmaceutical groups employ regional manufacturing entities under “limited-risk” models.
Setting appropriate markups for these arrangements ensures compliance with Transfer Pricing documentation standards and avoids profit misallocation.
Inconsistent access to reliable comparable data for specialized pharmaceuticals complicates Transfer Pricing studies.
A robust benchmarking approach and clear documentation framework help mitigate audit risks.
Each jurisdiction interprets OECD Transfer Pricing Guidelines differently.
Pharmaceutical companies must align their global documentation with local country files and master file requirements to ensure transparency and audit readiness.
The pharmaceutical industry faces heightened scrutiny due to high-value intangibles and complex structures.
Failure to provide defensible Transfer Pricing documentation can result in significant adjustments, penalties, and reputational risks.
our pricing

Clear, Competitive Packages Tailored for Your Transfer Pricing Needs

Basic Transfer Pricing Benchmarking

$2,500 (one-time)
Coverage:
Benchmarking analysis for a single intercompany transaction.
Deliverables:
Industry-specific benchmarking study
Arm’s length pricing support
OECD-compliant benchmarking documentation
Perfect for businesses that only need standalone benchmarking without full documentation.

Standard Transfer Pricing Study

$3,500 (one-time)
Coverage:
Comprehensive transfer pricing study for one transaction type.
Deliverables:
Functional and economic analysis
Selection of the most appropriate transfer pricing method
Benchmarking analysis
Documentation (Master File & Local File) in line with OECD and CRA guidelines
Designed for businesses requiring a complete transfer pricing report for CRA compliance.

Premium Transfer Pricing Study

$4,500 (one-time)
Coverage:
Financial transaction benchmarking or two types of transactions.
Deliverables:
Benchmarking for intercompany financial transactions (e.g., loans, guarantees)
Full documentation package (Master File & Local File)
Strategic pricing insights and documentation for high-risk or high-value transactions
Ideal for businesses with complex structures or cross-border financial arrangements.
Our Team Experts

Experienced Transfer Pricing Advisors at Your Service

faq

Transfer Pricing for Pharmaceuticals & Life Sciences Industry

Get clarity on the most common questions our clients ask about Transfer Pricing in the pharmaceuticals and life sciences sector.

Need Accurate Commodity Pricing and Stronger Compliance?

Cross-border transactions involving R&D, intellectual property, and product licensing are heavily scrutinized by tax authorities. Proper Transfer Pricing documentation ensures that royalties, service fees, and manufacturing margins meet OECD Transfer Pricing Guidelines and withstand audit challenges.

 

 

We prepare comprehensive Transfer Pricing studies including:

  • Master File and Local File documentation.
  • Benchmarking for manufacturing and distribution entities.
  • Royalty rate analysis for patents and know-how.
  • Cost-sharing and R&D allocation reports.

We perform IP valuation and royalty benchmarking using industry databases, ensuring that pricing for trademarks, formulations, and technologies reflects true market value under OECD principles.

Yes. We offer Transfer Pricing audit defense and dispute resolution services, supporting clients during CRA reviews and global tax authority inquiries with full documentation and reconciliation analyses.

Our team has advised leading pharmaceutical, biotechnology, and life sciences firms, with in-depth experience in R&D cost allocation, licensing arrangements, and distribution benchmarking.

We support clients globally, including Canada, the U.S., Europe, and Asia-Pacific, ensuring consistent and defensible Transfer Pricing documentation across all jurisdictions.