tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Engagements › Pinewood Street Pharma › Draft agreement: Purchase of finished medicines

Draft Agreement From The Policy

Purchase of finished medicines. Every clause is drafted from the transfer pricing policy and the functional analysis, and says where it came from. Anything the file does not settle is left open, in brackets.

Suggestion A draft, not an agreement. A signed agreement is on file; compare it on the Agreements page. It counts for nothing until it is confirmed, and then only as the practice's draft for the parties. Download As Text

  1. Supply agreement

    Between Pinewood Street Pharma AG (the Supplier) and Pinewood Street Pharma Cyprus Ltd (the Distributor).

    Source: Transaction record

  2. 1. Supply

    The Supplier sells finished goods to the Distributor, which resells them in its territory.

    Source: Transaction record

  3. 2. Prices

    Prices are set each year so that the Distributor earns an operating margin of 2.00% of its sales, with a year-end true-up.

    Source: Group transfer pricing policy §4

  4. 3. Payment

    Invoices are payable within 60 days.

    Source: Group transfer pricing policy

  5. 4. Risks

    Inventory risk is borne by the Supplier. Market risk is borne by the Supplier.

    Source: Functional analysis, risks

  6. 5. Arm's length

    The parties intend the terms to be at arm's length and will adjust them if a review shows they are not.

    Source: OECD Guidelines 1.6; Income Tax Law s.33(6)

  7. 6. Term and law

    Effective from 1 January of the year; [term, termination and governing law to be agreed by the parties].

    Source: Not in the file · open point