Analytical rigour
Evidence is separated from assumption and judgement from opinion. Conclusions are supported by disciplined reasoning rather than convention or expediency.
PETRUZZI Advisory
Clarity, Confidence and Defensible Judgement for Consequential Value Decisions
Expert-driven transfer pricing and valuation consultancy grounded in analytical rigour, practical insight, independent judgement, senior-level execution and tailored advice.
The Firm
A specialised boutique operating at the intersection of transfer pricing and valuation, combining business acumen, financial expertise, strategic thinking and an international expert network to support corporates, advisers and investors in transactions, disputes and regulatory affairs.
The PETRUZZI Advisory Difference
Senior judgement, institutional proximity and defensible positions.
Multidisciplinary thinking
With expertise spanning economic, accounting, strategy, tax, legal, and other disciplines, every matter is considered from multiple perspectives, ensuring the advice reflects the complexity of the situation.
Independent judgement
Free from audit and consulting relationships, organisational bias, and implementation incentives, recommendations are shaped solely by the case context and the strength of the underlying analysis.
Senior-led execution
Every engagement is led directly by senior specialists from the first conversation through to the final position, giving clients continuous access to the expertise they engaged from the outset.
Practical defensibility
Drawing on robust specialist experience and developed with long-term sustainability in mind, positions are designed to be technically credible, commercially workable, and capable of withstanding rigorous scrutiny.
Tailored advice
No two engagements are approached the same way. The scope, the specialists and the approach are shaped by what each matter actually requires, not by a standard methodology.
Representative Work
Anonymised examples illustrating the nature and breath of matters handled by PETRUZZI Advisory.
Dispute
Independent expert analysis of complex transfer pricing matters in the context of a cross-border dispute, integrating transfer pricing methodology, financial analysis and commercial considerations to develop technically robust and defensible positions.
Strategy & policy
Design of a transfer pricing policy for a highly integrated multinational structure, applying a profit split methodology to reflect non-routine contributions, interdependent activities and key value drivers.
Expert opinion
Independent expert opinion on a significant cross-border distribution arrangement, including transaction delineation, assessment of economically relevant characteristics and selection of the most reliable transfer pricing method.
M&A & intangibles
Development of a group-wide transfer pricing framework addressing acquisitions, ownership and post-acquisition management of brands, including DEMPE functions, intangible assets and post-merger integration.
Valuation
Independent valuation of assets in connection with a cross-border business restructuring, combining financial analysis, appropriate valuation methodologies and commercial judgement to support a robust and defensible assessment of value.
Business expansion & permanent establishments
Transfer pricing planning for an international market expansion through a permanent establishment, including functional profiling, allocation of functions, assets and risks, profit attribution, benchmarking and supporting documentation.
Why PETRUZZI Advisory
Trusted when the position must withstand scrutiny.
“PETRUZZI Advisory gave us a position we could actually defend, not one that simply looked reasonable on paper. That difference mattered enormously once the audit began.”
“Outstanding ability to transform complex transfer pricing concepts into practical business solutions. A trusted adviser for high-stakes international disputes.”
“PETRUZZI Advisory combined analytical rigour with sound business judgement, delivering conclusions that were both technically robust and commercially credible.”
“Exceptional expertise in OECD transfer pricing matters, combined with seamless communication and a pragmatic approach to complex business issues.”
“Deep technical expertise, reliable execution, and clear, commercially relevant advice. A trusted partner for navigating complex transfer pricing challenges.”
“Professional, proactive and highly responsive. PETRUZZI Advisory consistently delivers practical solutions and genuine value for clients.”
Featured Insights
Book
Transfer Pricing and Intangibles
A current examination of one of the field’s most consequential and contested areas.
ArticleThe Prescriptive Nature of the OECD Transfer Pricing Guidelines
Drawing the line between recommendations and requirements. International Transfer Pricing Journal 32 (6/2025).
NewsletterDevelopments that change the answer
Periodic analysis of what changed, why it matters, and the decisions it affects.
WebinarReasoning worked through openly
Technical sessions that examine positions, alternatives, and where an argument might fail.
Explore PETRUZZI Advisory