Strategic transfer pricing analysis for an international pharmaceutical expansion

MDDP provided expert transfer pricing advisory for a multinational pharmaceutical company, supporting the next phase of its international expansion under a licensing model. With subsidiaries across multiple jurisdictions and a network of global distribution agreements, the company sought to determine the arm’s length level of licensing fees for products manufactured abroad under a related entity’s brand.

This project presented significant challenges due to the complexity of licensing agreements and the highly specialised nature of pharmaceutical technology. MDDP’s experts applied an innovative, multi-stage analytical approach, integrating external databases with proprietary data provided by the company. By conducting a meticulous review of transaction terms and industry benchmarks, we delivered a robust justification for the applied transfer pricing model, ensuring compliance with international tax standards.

Our ability to combine deep industry knowledge with tailored analytical methods enabled the company to make strategic, data-driven decisions, reinforcing its international market position while minimising tax risk. This project exemplifies MDDP’s commitment to delivering cutting-edge, customised solutions in complex transfer pricing matters, supporting our clients in achieving sustainable global growth.

The project was led by Magdalena Marciniak (TP), in collaboration with Magdalena Dymkowska (TP).