From goods to data.
One arm's length principle.

FAQ

Where to start
among the disciplines.

• How many transfer pricing disciplines does PETRUZZI Advisory cover?

  Eight: goods, services, financing, intangibles, business restructurings, customs and VAT interaction, digital business transformation, and permanent establishments. Together they cover the OECD Transfer Pricing Guidelines end to end, not a curated subset.

• Do I need to know which expertise area applies to my case before contacting you?

  No. Most engagements begin as a general conversation about the fact pattern; Dr. Petruzzi identifies which discipline — or combination of disciplines — applies. Business restructurings, for example, routinely cross into intangibles and permanent establishments in the same file.

• How current is the guidance behind each expertise area?

  Each area is maintained against the live OECD Transfer Pricing Guidelines, including in-year updates — the November 2025 permanent establishment revisions and the 2026 Chapter VII low value-adding services consultation are both already reflected in the practice's working framework.

• Do you handle transfer pricing questions that touch more than one discipline at once?

  Yes, and most complex engagements do. A business restructuring, for instance, typically raises intangibles (DEMPE), exit charge valuation, and sometimes permanent establishment exposure in the same transaction — the practice analyses them as one connected question, not three separate ones.

• Does the expertise cover digital and platform business models?

  Yes, under transfer pricing for digital business transformation — SaaS, cloud, platform, and data-as-asset models that don't map cleanly onto traditional service or licence categories, plus Amount B (Pillar One) scoping for in-scope jurisdictions.

• Is permanent establishment risk part of the transfer pricing practice, or handled separately?

  Part of the same practice. PE risk and transfer pricing are functionally linked — a PE finding immediately raises a profit-attribution transfer pricing question — so they are analysed together rather than referred to a separate international tax team.

• How do you decide which OECD method applies to a given case?

  Method selection follows the OECD's 'most appropriate method' standard rather than a house default: CUP where genuine comparables exist, TNMM for routine functions, profit split where value is jointly created. The choice is documented and defended, not assumed.

• What happens after I identify which expertise area applies to my situation?

  The next step is usually a scoping conversation and a written scope letter, the same process described for any engagement — the expertise area determines the technical approach, not a different intake process. Most scopes close within a week of that first conversation.

• Does the expertise apply across industries, or is it sector-specific?

  The disciplines themselves are industry-agnostic — DEMPE analysis, method selection, PE risk assessment apply the same OECD framework regardless of sector — but the comparables, contracts, and value chains examined are always industry-specific. Automotive, pharma, and SaaS engagements draw on the same discipline with entirely different fact patterns.

• How does Dr. Petruzzi's academic research feed into the practical expertise areas?

  Directly. His role at the WU Transfer Pricing Center and his 24 books mean the expertise areas are updated from the same research pipeline that produces the practice's published output, not a separate 'client-facing' summary of the literature.