Her opdagede jeg virksomheden Royalty Pharma ($RPRX). De har en markedsvaerdi paa mere end 25 milliarder dollar, og jeg havde aldrig hoert om dem. Deres IPO var i juni.

De har ifoelge finviz.com 35 ansatte og tjener cirka 2 milliarder dollar om aaret.

Sammen med PBMerne ser det ift forretnings-modellen ud til at vaere yderligere en mellemmand.

Jeg gravede et par artikler frem, som maaske ogsaa vil vaere interessante for andre.

Meet The Secretive Wall Street Investor With The Billion Dollar Medicine Cabinet
https://www.forbes.com/sites/nathanvardi/2020/06/12/meet-the-secretive-wall-street-investor-with-the-billion-dollar-medicine-cabinet/#5adaf03bc361

The Private Equity Firm That Quietly Profits on Top-Selling Drugs
https://www.nytimes.com/2017/07/08/business/dealbook/drug-prices-private-equity.html

Deres skatte-konstruktion er i oevrigt interessant; og ikke mindre interessant med tanke paa den foreloebige afgoerelse mellem Apple og EU:
https://www.royaltypharma.com/node/7291/html

• We could be liable for significant taxes due to changes in our eligibility for certain income tax treaty benefits or challenges to our tax positions with respect to the application of income tax treaties.

Our subsidiaries expect to receive revenue from both U.S. and non-U.S. sources. We expect that our subsidiaries generally will be eligible for benefits under the applicable income tax treaty between Ireland and the jurisdiction where income is sourced. While we believe that our subsidiaries are currently eligible to claim the benefits of applicable income tax treaties between Ireland and the jurisdictions in which our income is sourced, no assurances can be provided in this regard, and it is possible that a taxing authority could successfully assert that any of our subsidiaries does not qualify for treaty benefits as a result of its failure to satisfy the applicable requirements to be eligible to claim treaty benefits. If a taxing authority were to challenge our position regarding the application of an applicable income tax treaty, we could become subject to increased withholding taxes, and such taxes could be significant.

Specifically, with respect to certain U.S.-source income, we expect that our subsidiaries will be eligible for benefits under the U.S.-Ireland income tax treaty (the "Treaty"), and, under that Treaty, will not be subject to any U.S. withholding taxes on such U.S.-source payments.

• U.S. Federal Income Taxation of the Company

While we do not expect to be engaged in the conduct of a trade or business within the United States or subject to U.S. taxation in that regard, we will be subject to United States federal withholding tax on certain fixed or determinable annual or periodical gains, profits and income, such as royalties from sources within the United States, unless reduced or eliminated under an applicable tax treaty or provision of the Code. Generally, this tax is imposed by withholding 30% of the payments, or deemed payments, that are subject to this tax. We expect that our subsidiaries will be eligible for benefits under the U.S.-Ireland income tax treaty, and, under that treaty, will not be subject to any U.S. withholding taxes on U.S.-source royalty payments, but no assurance can be given in that regard. See "Risk Factors-Risks Relating to Taxation-We could be liable for significant taxes due to changes in our eligibility for certain income tax treaty benefits or challenges to our tax positions with respect to the application of income tax treaties" for further information regarding the risk that we may not be entitled to treaty benefits.