Transfer Pricing Within The North American Pharmaceutical Industry: Has There Been A Structural Shift In Risk?
Bibliographic record
Abstract
Patent protection within the North American pharmaceutical industry has enabled pharmaceutical companies in the past to obtain a degree of exclusivity with respect to a particular market. This exclusivity is needed to provide drug companies with significant profits on winner drugs in order to offset the losses associated with the many failures that occur during the long developmental process. Laws in Canada that are designed to protect intellectual property have not been strong enough and have forced pharmaceutical companies to perform valuable research and development activity in other tax jurisdictions such as the United States. Within North America, a multinational pharmaceutical company is often structured in such a way that core research and development is performed in the U.S. with the marketing activity being done in Canada. However, changes to laws that seemingly favour generic drug manufacturers, coupled with regulations placed on marketing efforts have seeming shifted the risk towards the research and development effort and away from the marketing activity. This should alter the way tax authorities view the profits associated with the activities of various members of a multinational corporation with marketing receiving more routine returns and the core research and development activity receiving a greater potential for higher profits (and losses) due to increasing risks.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.001 |
| Science and technology studies | 0.001 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.006 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".