How does Pillar Two interact with new TP planning from 2026?

Pillar Two's top-up tax operates above the TP regime; the planning question is whether a TP position that is correct at arm's length still produces an acceptable effective rate after the IIR, UTPR, and QDMTT. The planning memorandum models the interaction explicitly.

Does Planning and Strategy advice address Amount B (Pillar One)?

Yes, where the jurisdiction is covered. Amount B applies a fixed return to baseline marketing and distribution. The planning memorandum identifies whether the proposed routine distributor or marketing company falls within the safe harbour, and where the boundaries sit.

Can the design memorandum be relied on by tax authorities?

It is drafted as a citable document. It is typically attached to the Master File, cited in the Local File rationale, and shared with the competent authority when an APA or advance ruling is sought.

How early should the engagement start before a structure is implemented?

Six to twelve weeks before legal incorporation is the most common timing. That gives time for substance to be mapped, the OECD framework to be applied, and the design memorandum to be reviewed before any commitment is irrevocable.

Does the same advisor deliver the implementation work later?

Optionally. The methodology, policy, and benchmark studies the structure requires after implementation can be delivered by PETRUZZI Advisory under separate engagement, or by the client's existing TP advisor with the design memorandum as the reference document.

Planning and Strategy

Editorial photograph of a modern strategy room: a glass wall etched with an abstract transaction-structuring diagram in deep navy ink and warm gold accent nodes.

The Service

Pre-transaction transfer pricing design. Structure, substance, and the OECD framework, set against the post-BEPS standard from day one.

The Service

What is Planning and Strategy in transfer pricing?

Planning and Strategy is the pre-transaction design of intra-group transactions. Before the structure is put in place, the allocation of functions, assets, and risks is set against the OECD framework, substance is real and documented, and the Pillar Two interaction is mapped. The file inherits a defensible position.

Most TP problems start before the file exists. A structure is implemented for non-tax reasons, then the TP advisor is asked to rationalise it. Planning and Strategy inverts that sequence. The TP design is part of the structural design from day one, drafted to the post-BEPS standard, with Pillar Two GloBE rules and Amount B safe harbour eligibility taken into account from 2026 forward.

The Difference

Why retain an independent advisor for Planning and Strategy?

The Answer

Pre-transaction design needs an advisor who is not selling a tax product downstream. PETRUZZI Advisory has no compliance pipeline, no Pillar Two software, and no APA-as-a-service offering to protect. That removes the structural bias that turns planning advice into the sale of a future revenue stream.

When it Fits

When should you retain Planning and Strategy advice?

Common triggers from prior engagements.

Before a new entity is incorporated, a function migrates, or an IP holding company is established.
Before a financing structure is implemented under Chapter X conditions.
When a Pillar Two top-up exposure has to be modelled against the existing TP profile.
When a transaction will trigger an Amount B reallocation in a covered jurisdiction.
When a structure is being reviewed for board approval and the TP risk profile is part of the assessment.

The Methodology

How does PETRUZZI Advisory deliver Planning and Strategy?

Four-step sequence, run before any structural decision is taken.

Step 01
Structure walkthrough
A working session with the in-house team and legal or structural advisors to understand the commercial intent, the proposed entities, and the timing constraints.
Step 02
Substance mapping
Identification of where functions, assets, and risks will actually sit post-implementation. Substance is documented before it is asserted; the file does not rely on legal allocations alone.
Step 03
OECD application
The proposed structure is tested against the relevant OECD chapter and any BEPS Action that bears. Pillar Two interaction is modelled where it is material. Amount B is applied where the jurisdiction is covered.
Step 04
Design memorandum
A written design memorandum and decision record. Signed by Dr. Petruzzi and carried with the structure into implementation, compliance, and any future controversy.

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
Designs the TP model before the structure is implemented, not as an after-the-fact rationalisation.
02
Pillar Two compatibility built into every plan from 2026 forward.
03
Aligns allocation of functions, assets, and risks with the post-BEPS framework before incorporation.
04
Output is a design memorandum and a defensible decision record the file carries forward.

Related Expertise

Where this connects.

Intra-group loans, guarantees, cash pools, captives. OECD Chapter X through the lens of the Petruzzi monograph.

Chapter IX applied to your structure. Exit charges, post-restructuring remuneration, recharacterisation risk.

Cloud, SaaS, platforms, data IP, under the OECD framework and Pillar One/Two.

Back to all services

FAQ

Planning and Strategy.Designed for the file before it exists.

What is Planning and Strategy in transfer pricing?

Why retain an independent advisor for Planning and Strategy?

When should you retain Planning and Strategy advice?

How does PETRUZZI Advisory deliver Planning and Strategy?

Structure walkthrough

Substance mapping

OECD application

Design memorandum

How an engagement runs.

Inquiry

Scoping

Analysis

Recommendation

Implementation Support

The essentials, in their own words.

Where this connects.

Transfer Pricing for Financing

Transfer Pricing for Business Restructurings

TP and Digital Business Transformation

Questions on planning and strategy.The ones that come up first.

Questions on planning and strategy.
The ones that come up first.