The Service
Master File, Local File, Country-by-Country Reporting. Drafted to the standard a Big Four reviewer would expect, designed to defend the position rather than merely file it.
The Service
What does Compliance cover?
Compliance covers the three documentation tiers introduced by BEPS Action 13: the Master File at group level, the Local File at entity level, and the Country-by-Country Report. Each tier is drafted to defend the underlying position, not just to satisfy the format requirement.
Documentation is the first thing a tax authority opens in an audit. A Local File that reads as a templated output is treated as one. A Local File drafted to the standard of a defensible legal memorandum, with OECD-paragraph rigor, evidence anchors, and explicit treatment of the residual risks, frames the audit on the taxpayer's terms.
The Difference
Why retain PETRUZZI Advisory for Compliance work?
The Answer
Big Four compliance is volume work; the file reflects the workflow that produced it. PETRUZZI Advisory does selective compliance for groups whose positions are technically demanding. Each Local File is drafted by Dr. Petruzzi or under his direct review, signed in his name, and defensible in the same hand.
When it Fits
When should you retain PETRUZZI Advisory for Compliance work?
Common triggers.
When the group has a technically demanding position (Chapter X financing, DEMPE, business restructuring) and the documentation has to defend it on first reading.
When the existing compliance provider has produced a template the in-house team finds indefensible at audit.
When a Local File has been challenged in audit and the next year's filing has to be re-anchored.
When a short-notice filing in Austria, Germany, Italy, or Switzerland requires surge capacity.
When the group is preparing for an ICAP or EU ETACA process and the Master File becomes the entry document.
The Methodology
How does PETRUZZI Advisory deliver Compliance?
Documentation is built around the policy. The sequence:
Step 01
Policy reference
The compliance file references the group TP policy or the underlying memoranda. If no policy exists, a baseline is set first.
Step 02
Master File
Drafted at group level on the OECD Action 13 perimeter, with technical depth on the structural transactions that drive the group's TP profile.
Step 03
Local Files
Per entity, drafted as a defensible legal memorandum. Functional analysis is anchored in evidence; method selection is reasoned; comparable selection is documented with rejection criteria explicit.
Step 04
CbCR review
The CbCR is reviewed for consistency with the Master File, Local Files, and the Pillar Two GloBE data feed where the group is in scope.
Step 05
Filing calendar
Per jurisdiction, deadlines and renewal cycles are tracked. Where local pre-clearance or filing-with-return rules apply (Austria, Italy), the timing is part of the deliverable.
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
Master File, Local File, and CbCR drafted in line with OECD Action 13 and the local implementations across AT, DE, IT, and CH.
- 02
Documentation is built around the policy and the rate card, not generated retrospectively.
- 03
Jurisdiction-specific deadlines tracked across the EU; surge support for short-notice filings.
- 04
Each Local File reads as a defensible legal memorandum, not a templated output.
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