A US Life Science multinational corporation was applying for an APA between the United States and Ireland for intangible related transactions in a business area where it is global market leader. The analysis for intangible related solutions is CUP based, but the US headquarters was concerned about the quality and few numbers of comparables, as well as the resulting wide range of outcomes. The MNC was concerned it could not control the outcome of the APA with such analysis.

To support the solution for which it has filed an application, client asked NERA to corroborate the proposed solutions through a Shapley value analysis that, in line with OECD 2017, considers the cross-fertilization of functional contributions to intangible value drivers. NERA’s analysis allowed the MNC to narrow down the range of plausible results within the range of the CUP analysis.