Transfer pricing within the North American pharmaceutical industry : has there been a structural shift in risk?

The pharmaceutical industry receives much attention from tax administrations, legislators in various fields and, last but not least, transfer pricing specialists. This attention is directed inter alia on the profitability of the various functions that may be present in various countries. This article describes the possible consequences of several recent changes (particularly those in Canada) for the allowed profitability of R&D activities. Considering the focus on the alleged profitability of e.g. marketing and distribution activities, the author states his reasons for fearing that the high returns for R&D activities, needed to make their busines a success, are being diminished.