Transfer pricing

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Pharma tariffs still have a lot of questions outstanding, says Bernstein's Courtney Breen
Youtube· 2025-09-26 17:47
Joining us now, Courtney Breen, senior analyst at Bernstein, covering US Pharma, Bioarma. Courtney, great to have you with us. Um, obviously there's still some some questions outstanding.I'm I'm wondering if you're you know, as you think about companies with US manufacturing, if companies have pre-existing plants, are they also exempt. I think what we've had so far is a a tweet or a post uh on on truth social rather than necessarily the discreet and detailed policy. So I think there are a lot of questions t ...
Franco-Nevada Reaches Settlement on Canadian Tax Disputes
Prnewswire· 2025-09-11 21:42
Core Insights - Franco-Nevada Corporation has reached a settlement with the Canada Revenue Agency (CRA) regarding tax disputes related to transfer pricing for the years 2013 to 2019 [1][3][7] - The settlement allows Franco-Nevada to avoid paying taxes in Canada on foreign earnings from its subsidiaries during the specified years [7] - The adjustment in service fees will increase the mark-up on costs from 7-20% to 30%, resulting in an additional taxable income of C$1.4 million [7] Settlement Details - The settlement resolves the tax dispute and provides greater investment certainty for Franco-Nevada's global growth ambitions [3] - Transfer pricing penalties from the reassessments will be reversed, and interest charges will be adjusted accordingly [7] - The settlement is not legally binding for years after 2019, but the established transfer pricing principles are expected to apply unless there are material changes [7] Company Overview - Franco-Nevada is a leading gold-focused royalty and streaming company with a diversified portfolio of cash-flow producing assets [5] - The company utilizes its free cash flow to expand its portfolio and pay dividends, trading under the symbol FNV on both the Toronto and New York stock exchanges [5] - Over the last 18 months, Franco-Nevada has completed approximately $3 billion in transactions to enhance its asset portfolio [3]