The Service
Customised programmes for in-house tax teams, finance leadership, and advisors. WU Transfer Pricing Center curriculum, adapted to the questions your group actually faces.
The Service
What do PETRUZZI Advisory Trainings cover?
Trainings cover the full transfer pricing curriculum used at the WU Transfer Pricing Center, adapted to the specific questions a group faces. Programmes range from one-day technical workshops for in-house teams to multi-day capacity programmes for public institutions.
The curriculum is grounded in the WU LL.M. in International Tax Law and the WU Transfer Pricing Center's Certificate programme. Dr. Petruzzi as Managing Director of the Center signs off on every programme. The depth is academic; the application is practitioner.
The Difference
Why retain PETRUZZI Advisory for Trainings?
The Answer
Big Four internal training is typically generic and template-driven. PETRUZZI Advisory training is customised: case studies are the group's own (anonymised where required); the framework is the WU Transfer Pricing Center curriculum; delivery is by Dr. Petruzzi or a senior WU-affiliated colleague.
When it Fits
When should you retain a Trainings engagement?
Common triggers.
When an in-house tax team needs to up-skill ahead of a major transaction (restructuring, IP migration, Chapter X financing).
When a finance leadership team needs the TP basics for Pillar Two GloBE reconciliation.
When external advisors need depth on a specific OECD chapter (Chapter VI DEMPE, Chapter X financing, Chapter IX restructurings).
When a public institution needs capacity-building on TP under the UN Practical Manual.
When a board or audit committee needs an executive briefing on TP risk profile and Pillar Two interaction.
The Methodology
How are training programmes designed and delivered?
Four-step process from inquiry to delivery.
Step 01
Needs scoping
A short conversation to identify the audience, the level, the topics, and the timeframe. The output is a programme outline and a fee letter.
Step 02
Curriculum design
The curriculum is drafted from the WU Transfer Pricing Center programme, customised to the audience's questions and the group's transactions.
Step 03
Case studies
Case studies are drafted from anonymised group transactions where the engagement permits, or from leading case law where it does not.
Step 04
Delivery and follow-up
Delivery in person (Vienna or onsite) for most programmes; virtual for smaller workshops. A follow-up note recaps the key takeaways and the open questions for further engagement.
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
Customised training for in-house tax teams, finance leadership, and external advisors.
- 02
Public-institution capacity programmes where the UN, EU, or OECD dimension applies.
- 03
Curriculum drawn from the WU Transfer Pricing Center LL.M. and Certificate programmes.
- 04
Delivered in person in Vienna or onsite; smaller programmes by virtual delivery.
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.
Cloud, SaaS, platforms, data IP, under the OECD framework and Pillar One/Two.
FAQ