The Service
Independent opinions and second opinions on specific transfer pricing questions. Peer-reviewed reasoning, OECD-anchored, written to defend in front of a tax authority.
The Service
What does the Advisory service do?
Advisory delivers written, citable opinions on discrete transfer pricing questions: a method choice, a comparability dispute, a Chapter X characterisation, a DEMPE attribution, a Pillar Two interaction. Each opinion sets out the framework, applies the facts, and states a position the client can rely on in audit, MAP, or litigation.
The output is a memorandum signed by Dr. Petruzzi. It cites the OECD paragraph or BEPS Action that governs the question, sets out the comparability evidence where it matters, and identifies the residual risk honestly. Most engagements are short and scoped to a single issue. A few extend into a series of opinions across a structure where the position has to be carried forward across years.
The Difference
Why retain an independent advisor for Advisory work?
The Answer
The Big Four cannot give you a second opinion on a position they wrote, audited, or sold. PETRUZZI Advisory has no firm-wide TP position, no underlying audit relationship, and no recurring tax-compliance product to protect. That is the only condition under which a second opinion is genuinely independent.
When it Fits
When should you retain PETRUZZI Advisory for Advisory work?
Common triggers from current and prior engagements.
An existing advisor's opinion needs independent peer review before a controversial position is filed.
A pre-audit position requires a second view because the original advisor is also the auditor or has firm-wide alignment risk.
A specific OECD paragraph or BEPS Action turns on a substance question that needs academic-grade reasoning, not a templated memorandum.
An expert witness opinion is required in MAP, arbitration, or domestic court.
A board or audit committee asks for an independent risk assessment of an existing TP position.
The Methodology
How does PETRUZZI Advisory deliver an Advisory engagement?
Four-step delivery, scoped individually, never templated.
Step 01
Issue framing
A short conversation with the in-house team or external advisor to define the question precisely. The framing letter sets the scope, the framework, and the deliverable.
Step 02
OECD analysis
Substantive review of the applicable OECD chapter and any BEPS Action that bears. Comparability evidence assembled to the standard a Big Four reviewer would expect, with named cases cited where they sharpen the answer.
Step 03
Written opinion
A memorandum that states the position, the framework that supports it, the facts that anchor it, and the residual risk the file still carries. Signed by Dr. Petruzzi.
Step 04
Follow-up
Ongoing access while the matter develops. If the position is later challenged in audit or MAP, the same hand defends it.
The Engagement
How an engagement runs.
Inquiry
A short conversation to understand what's on the file: the structure, the timeline, the existing advisors.
Scoping
A written scope and fee letter. Concrete deliverables, dates, and the answer to who reviews what.
Analysis
Substantive work delivered by Dr. Petruzzi personally. OECD-paragraph rigor; named cases; citeable conclusions.
Recommendation
A written opinion or report. Sets out the framework, the facts, the application, and the residual risk.
Implementation Support
Implementation, follow-up, and ongoing access as the matter develops. The engagement doesn't end at delivery.
Key Takeaways
The essentials, in their own words.
- 01
Independent written opinions on discrete transfer pricing questions, drafted to defend in audit, MAP, or court.
- 02
Second opinions where the existing advisor has a structural conflict, a firm-wide position, or a recurring product to protect.
- 03
Expert witness work in select matters; engagements scoped individually, conflicts screened in advance.
- 04
Delivered personally by Dr. Petruzzi. The file carries the same name that signs it.
Related Expertise
Where this connects.
Intra-group loans, guarantees, cash pools, captives. OECD Chapter X through the lens of the Petruzzi monograph.
Identification, attribution, valuation, and dispute defence through the DEMPE framework.
Chapter IX applied to your structure. Exit charges, post-restructuring remuneration, recharacterisation risk.
FAQ