The Service
Design and implementation of group-wide transfer pricing policy. The documentation rhythm that keeps the position audit-ready year after year.
The Service
What is a group-wide transfer pricing policy?
A group-wide TP policy is a single document that sets out how every intra-group transaction in the group will be priced, by whom, with what method, and against what data. It translates the OECD framework into the operational rules a multinational uses day to day, and gives the audit file its through-line.
Without a policy, every intra-group transaction is repriced from scratch each year. With a policy, the method, the comparable set, the adjustment triggers, and the documentation cadence are set in advance and reviewed against actuals at year-end. The policy is the file's most cited document in audit.
The Difference
Why retain an independent advisor for Policy design?
The Answer
Big Four policies often default to a TNMM-heavy template optimised for the firm's audit-and-document workflow. PETRUZZI Advisory designs to the structure, not to the workflow. Classical methods lead where comparability supports them; TNMM applies where it must; the policy carries the technical reasoning, not just the conclusion.
When it Fits
When should you retain a Policy design engagement?
Common triggers.
After a restructuring has changed the functional profile of one or more entities.
When the existing policy is more than five years old and pre-dates BEPS Actions 8-10 or Chapter X.
When an audit has surfaced a method or comparability weakness that needs a structural fix.
When the group is moving to operational TP technology and needs a policy the system can be configured against.
Before a new compliance year where the documentation rhythm has to be reset.
The Methodology
How does PETRUZZI Advisory deliver Policy design?
Five-step engagement, paced around the group's compliance calendar.
Step 01
FAR baseline
Functions, assets, and risks across the group are mapped per entity, with substance evidence sufficient for Chapter I of the Guidelines.
Step 02
Method selection
Per transaction category, the appropriate method is selected and reasoned. CUP, RPM, or CP leads where comparability supports it; TNMM applies where it must; profit splits are reserved for the cases that require them.
Step 03
Rate card and adjustment triggers
Per category, the rate range, the comparable set, and the year-end adjustment triggers are documented in a single rate card the operational team can run against.
Step 04
Governance and roles
Policy ownership, monitoring, and dispute handling are defined. OTP technology fit is assessed where the group is large enough to need it.
Step 05
Documentation cadence
The Master File, Local File, and intercompany agreements are aligned to the new policy in the first compliance year.
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
Group-wide TP policy design that ties the arm's length principle to specific rate cards, methods, and adjustment triggers.
- 02
Implementation support: governance design, role definition, operational TP (OTP) technology fit assessment.
- 03
Annual review and update cadence built into the engagement so the policy keeps pace with regulatory drift.
- 04
Designed to align Master File, Local File, and CbCR obligations from the policy's first year.
Related Expertise
Where this connects.
Methodology, comparability, and the OECD framework, applied to the way goods are priced within a group.
Beyond the 5% mark-up. Where low value-adding rules apply, and where they don't.
Intra-group loans, guarantees, cash pools, captives. OECD Chapter X through the lens of the Petruzzi monograph.
FAQ