Independent transfer pricing.
Peer-reviewed at every turn.

FAQ

The conversations.
That come up first.

• How is PETRUZZI Advisory different from a Big Four practice?

  We are independent by construction: a single principal, no audit conflicts, and no incentive to recommend the answer that grows the next engagement. Dr. Petruzzi delivers every opinion personally, from the WU Transfer Pricing Center and the UN Subcommittee chair.

• What does a typical engagement look like?

  A scoping conversation, a written scope and fee letter, then the substantive work: an expert opinion, a transfer pricing analysis, or audit and litigation support. Most engagements complete in weeks, not months.

• Do you accept clients with a Big Four firm already on the file?

  Yes. Second opinions are one of our most-requested engagements. Our role complements the file rather than replacing it, and the independence cuts both ways: we say what we see, including where we agree with the existing analysis.

• Where do you work, geographically?

  Vienna is the base; engagements cover the EU, the DACH belt, and globally where the analysis demands the WU and UN academic anchoring. Our clients are multinationals; the work follows them across borders.

• Do you provide expert testimony in court or before a tax authority?

  Yes. Dr. Petruzzi writes expert opinions intended for filing with tax authorities, MAP procedures, and court proceedings. The standard is the academic-peer-review one: framework cited, named cases applied, residual risk surfaced explicitly.

• How are your fees structured?

  Fees are quoted in a written scope letter before work begins. Most engagements are fixed-fee against a defined deliverable; standing-counsel retainers are available for groups that need ongoing access. We do not invoice in time-spent increments.

• How quickly can we start?

  Initial response within one business day. Most scopes close within a week. Urgent matters (a notice deadline, a pending audit, a board-level decision) can compress to days; tell us the deadline and we work backwards.

• Do you handle Advance Pricing Agreements (APAs)?

  Yes. Dr. Petruzzi advises on unilateral and bilateral APA applications, from the pre-filing conversation with the tax authority through the negotiated agreement. The same academic rigor that underpins our opinions carries into the APA's economic analysis and risk assessment.

• Do you work directly with corporate tax teams, or only through referring counsel?

  Both. Many engagements come directly from a group's in-house tax director; others arrive through law firms or Big Four teams seeking an independent second opinion for a client. Either way, Dr. Petruzzi is the one signing the work.

• What languages do you work in?

  English, German, and Italian for both spoken advice and written deliverables; opinions can be filed in any of the three depending on the authority or court. Vienna's DACH position and Dr. Petruzzi's Italian academic roots make trilingual work the norm, not the exception.