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PETRUZZI PERSPECTIVES

Insights & Publications

Perspectives, case analysis and policy commentary on transfer pricing and valuation.

Tax Policy Challenges in the 21st Century

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Transfer Pricing Aspects of Intra-Group Financing

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Transfer Pricing in a Post-BEPS World

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Transfer Pricing Developments Around the World 2017

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Fundamentals of Transfer Pricing: A Practical Guide

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Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions

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Substance in Transfer Pricing in a Post-BEPS World and Beyond…

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Transfer Pricing Rules Under EU Law and the CJEU’s Decision in Impresa Pizzarotti

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The OECD’s Proposed Changes to the Commentary on Article 9 (and Related Articles): A Critical Analysis

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Il Caso Tetra Pak: L’inizio di una Nuova Era nei Controlli Fiscali relativi ai Prezzi di Trasferimento?

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Pillar One, Pillar Two, Transfer Pricing and the Arm’s Length Principle: A Tangled Web of New and Old Taxing Rules

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The EC’s Proposal for a Directive on Transfer Pricing: Paving the Road for a Common Application of the Arm’s Length Principle

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Non-deduction of Interest Payments and Third Countries

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The Dependent Agent PE as an Extension of the PE Concept of Article 5 paragraph 1 OECD Model Convention

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Il Transfer Pricing nei Rapporti con Società Estere del Gruppo

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The Baseball Arbitration in Comparison to Other Types of Arbitration

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Permanent Establishments: Proposals Related to Agency Permanent Establishments – Article 5(5) and (6) of the OECD Model Convention

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The Arm’s Length Principle: Between Legal Fiction and Economic Reality

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