CRA provides written testimony on pharmaceutical marketing efforts as part of a transfer pricing dispute

CRA was retained by counsel on behalf of a UK based pharmaceutical company as part of a transfer pricing dispute with the IRS. The IRS claimed they were owed additional tax revenue associated with a number of products sold, based on an exceptional marketing effort in the US associated with these products. Dr. Gregory Bell was asked to provide written testimony on pharmaceutical marketing efforts executed by the company. There were a number of drugs at issues but central to the case was the use of a co-promotion deal that made a novel drug very successful. Dr. Bell detailed the marketing strategy for the drugs at issue relative to what was contemporaneous industry standard. This included such activities as DTC, detailing, sampling, CME, and other promotional means.