The Service
Mutual Agreement Procedures, mandatory binding arbitration, and the EU Tax Dispute Resolution Directive. Cross-border controversy delivered to settlement.
The Service
What does Dispute Resolution cover?
Dispute Resolution covers cross-border TP controversies after audit: MAPs under treaties and under the EU Tax Dispute Resolution Directive (DRD 2017/1852), and mandatory binding arbitration where the treaty supports it. The engagement runs from MAP filing to settlement or arbitration award.
Once a TP audit results in a double-taxation outcome, the MAP procedure is the route to relief. Dr. Petruzzi's UN Subcommittee role and decade-plus history of competent authority work give the file standing in the procedure that other advisors cannot replicate.
The Difference
Why retain PETRUZZI Advisory for Dispute Resolution?
The Answer
MAP is a competent-authority-to-competent-authority negotiation; the taxpayer's role is to deliver the technical position. Dr. Petruzzi is a named member of the UN Subcommittee on Transfer Pricing and a regular contributor to OECD MAP-related publications. The technical position is delivered with academic standing.
When it Fits
When should you retain Dispute Resolution support?
Common triggers.
After an audit adjustment that produces unrelieved double taxation.
Where MAP negotiations have stalled and arbitration becomes the route to resolution.
Under the EU Tax Dispute Resolution Directive where the two-year MAP deadline has passed.
Where multiple jurisdictions are involved and the MAP filings have to be coordinated across competent authorities.
Where a prior MAP has produced an agreement that requires implementation across multiple periods.
The Methodology
How does PETRUZZI Advisory deliver Dispute Resolution?
Five-stage engagement, paced through the competent authority calendar.
Step 01
MAP eligibility review
Treaty MAP, EU DRD MAP, or both: the eligibility is reviewed against the treaty article and the procedural rules of each competent authority.
Step 02
MAP filing
The MAP request is drafted with the technical position the procedure will turn on. Functional analysis, benchmark, and double-taxation calculation are presented to both competent authorities.
Step 03
Competent authority liaison
Through the procedure, PETRUZZI Advisory liaises with the lead competent authority, providing technical clarifications and counter-arguments as the negotiation develops.
Step 04
Arbitration trigger
Where MAP fails or the two-year EU DRD deadline expires, arbitration is triggered under the treaty or under the DRD.
Step 05
Implementation
Once the MAP agreement is signed or the arbitration award is rendered, the adjustment is implemented across the relevant periods. Reconciliation with CbCR and Pillar Two GloBE follows.
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
MAP under treaties and under the EU Tax Dispute Resolution Directive (DRD 2017/1852).
- 02
Mandatory binding arbitration where the treaty or the EU DRD supports it.
- 03
Audit-to-MAP-to-arbitration handover designed so each stage builds on the last.
- 04
Direct competent authority liaison; Dr. Petruzzi's UN Subcommittee role grants standing the procedure recognises.
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.
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