The Service
Valuations of intangibles, business units, and financial instruments. Priced for both arm's length and the audit that follows.
The Service
What does Valuations cover?
Valuations covers intangible valuations under Chapter VI, business unit valuations for Chapter IX exit charges or post-acquisition reallocations, and financial-instrument valuations under Chapter X. The output is a valuation report that travels with the file into audit, APA, MAP, or court.
Transfer pricing valuations are different from accounting valuations. The discount rate has to be defensible against arm's length comparable evidence, not just a CAPM build. Cash flows have to map to the DEMPE-attributed economic ownership, not just the legal title. The exit charge has to reckon with the options realistically available, not just legal entitlement.
The Difference
Why retain an independent advisor for Valuations?
The Answer
Accounting and audit-firm valuations are built for IFRS or US GAAP, not for OECD Chapter VI. PETRUZZI Advisory delivers OECD-anchored valuations: DEMPE-attributed cash flows, comparability-supported discount rates, HTVI provisions, and explicit treatment of the residual risks.
When it Fits
When should you retain Valuations?
Common triggers.
Pre-transaction valuation of an intangible being licensed or transferred intra-group.
Exit-charge valuation in a business restructuring under Chapter IX.
Financial-instrument valuation for an intra-group loan, guarantee, or hybrid under Chapter X.
Captive insurance pricing under §10.180-10.193.
Defensive valuation update where a prior valuation is being challenged in audit or MAP.
The Methodology
How does PETRUZZI Advisory deliver Valuations?
Each valuation is anchored in transaction-derived evidence.
Step 01
Substance and ownership
Legal ownership is documented; DEMPE substance is reviewed; economic ownership is attributed. For HTVI assets, ex-post adjustment provisions are scoped at the design stage.
Step 02
Cash-flow modelling
Cash flows are modelled to the DEMPE attribution, not the legal title. Forecast assumptions are documented and stress-tested. Terminal-value methodology is reasoned.
Step 03
Discount-rate calibration
Discount rate is calibrated using transaction-derived comparable evidence where available, or built from CAPM with explicit comparability adjustments. The risk premium is documented.
Step 04
Sensitivity and HTVI
Sensitivity tables are produced on the key assumptions. HTVI provisions are drafted into the intercompany agreement where the asset qualifies.
Step 05
Valuation report
A written report sets out the methodology, the inputs, the result, the sensitivities, and the residual risks. Signed by Dr. Petruzzi.
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
Intangible valuations under OECD Chapter VI methodology, with DEMPE-anchored substance review.
- 02
Business unit valuations for restructuring exit charges (Chapter IX) and post-acquisition price allocation.
- 03
Discount-rate calibration with explicit comparability evidence, not benchmark templates.
- 04
HTVI (Hard-to-Value Intangibles) provisions built into the valuation file from the start.
Related Expertise
Where this connects.
Identification, attribution, valuation, and dispute defence through the DEMPE framework.
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.
FAQ