The transfer-pricing input is the arm’s-length documentation lens. PharmaDB surfaces the third-party API percentile band and the supporting FDF realized price for the documentation memo. Refresh cadence is weekly.
Surface the arm's-length pricing range from declared API trade. The empirical benchmark documentation for intercompany API pricing across group entities.
Dasatinib API clears at $4,886/kg median with a $3,777-to-$8,428 interquartile band across 7 active suppliers. The arm's-length range is the defensible TP window: any intercompany price between p25 and p75 sits within the externally validated band. The corresponding FDF realized price on the 50mg / 60-tab pack clears at $10.65, supporting the API range with the downstream-margin coherence. The brief produces the documentation memo: API median $4,886, FDF median $10.65, embedded API per pack $14.66 (a tight conversion margin), with 7 supporting third-party observations in the year.
Type the API INN and the proposed intercompany price. The AI agent pulls the third-party clearance band and checks whether the proposed price sits within the defensible range.
p25, median, p75, and the supplier count are returned with the proposed-price chip. A chip flags 'within range' (p25 to p75) or 'outside range' (above or below) for the transfer-pricing file.
Citation-anchored brief structured as a transfer-pricing supporting memo: the arm's-length range, the proposed price position, the supporting FDF realized price, and the trimmed shipment count as the third-party comparability anchor.
The arm's-length range is built from declared third-party trade. The supplier count gives the comparability anchor: 7 third-party observations on dasatinib supports a defensible TP file.
The proposed intercompany price is checked against the p25-to-p75 range. Within range: defensible. Outside range: requires either a price adjustment or a supporting argument for the deviation.
FDF realized price provides the downstream check. A high API price requires a matching FDF margin; the brief surfaces both so the TP file is internally coherent.
API and FDF aggregates refresh weekly. The TP range is current; the documentation memo carries the exact computation timestamp.
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pharmagraph_query Twelve molecules · 2024 arm's-length p25-to-p75 range · USD/kg · with third-party supplier count as the comparability anchor.
The transfer-pricing input is the arm’s-length documentation lens. PharmaDB surfaces the third-party API percentile band and the supporting FDF realized price for the documentation memo. Refresh cadence is weekly.
The price that unrelated parties would agree to under comparable conditions. OECD and most national tax authorities require intercompany pricing to fall within the defensible arm's-length range. PharmaDB builds the range from declared third-party trade as the external comparable.
Tax-authority practice varies. A common standard is the interquartile range (p25 to p75) of comparable third-party transactions. Some jurisdictions accept the full range with adjustments. PharmaDB outputs both for documentation flexibility.
Depends on jurisdiction and the materiality of the transaction. As a rule of thumb, 5+ third-party observations on the same molecule in the same year are sufficient for most TP files. PharmaDB surfaces the count alongside; under 5, the brief flags a comparability concern.
TP authorities check the entire value chain for coherence. A high intercompany API price needs a matching downstream FDF margin to be defensible; if the FDF margin is thin, the high API price is challenged. The brief surfaces the FDF realized price for the same molecule as the downstream check.
Two options. Adjust the price into range (the conservative approach). Or provide a supporting argument: the related parties bear different risks, the proposed price reflects a long-term contract, the comparability set is imperfect. The brief flags the position and prompts for the deviation argument.
API and FDF aggregates refresh weekly. The arm's-length range reruns on every refresh; the documentation memo carries the exact computation timestamp.
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