Fundamentals of Transfer Pricing : Principles and Practice

Dr Raffaele Petruzzi, LLM is the managing director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the founder and CEO of PETRUZZI Advisory, and an independent advisor on international tax and transfer pricing matters. He is also a member of the United Nations Subcommittee on Transfer Pricing. Raffaele gained extensive experience by working for many years within big four firms, international law firms, and in-house positions. He regularly advises clients across numerous industries on international tax and transfer pricing issues and provides assistance on risk management and compliance, international tax planning and strategy, policy design and implementation, valuation of companies and intangible assets, tax audit defence, implementation of mechanisms of dispute avoidance and resolution, and training programs. Raffaele is a frequent speaker at international conferences and lecturer of numerous courses all over the world, as well as author of many publications. He regularly cooperates with professionals in advisory, the business community, governments and international organizations such as the OECD, the United Nations, the World Bank Group, the International Monetary Fund, and the European Commission. Amongst others, he is an editor of Linde Transfer Pricing International Journal and a member of the International Fiscal Association (IFA), of the International Bar Association (IBA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a PhD in International Business Taxation from WU, an LLM in International Tax Law from WU, and an MSc in Business Administration and Law from Bocconi University. Raffaele contributed to Chapters 1, 2, 11, and 12 of this volume.

Dr Giammarco Cottani is an international tax and transfer pricing expert. Previously, Giammarco worked as the head of tax at Agoda where he led the tax function of the group and also as the director of global tax policy at Netflix where he spearheaded the tax public policy-related issues that the group faced in the countries in which Netflix operates. Before that, Giammarco was a partner of the international tax law firm of Ludovici Piccone & Partners where he coordinated the international and transfer pricing practice. Giammarco was also involved in several projects for the tax administrations in several LATAM/developing countries and served as a member of the UN Sub-Committee Group in charge of the Draft of the Practical Manual on Transfer Pricing for Developing Countries. He was an adviser to the Italian tax authorities on international tax and transfer pricing issues from 2011 to July 2015 and was one of the delegates for Italy on the OECD BEPS Project. He has (co-)led over twenty events in transfer pricing when working as a transfer pricing adviser in the transfer pricing unit of the OECD. Giammarco received his degree in law from LUISS Rome University in 2003, an LLM in European and International Taxation from the European Tax College in 2005, and a PhD in Corporate Taxation from LUISS University in 2009. Giammarco contributed to Chapters 1 and 13 of this volume.

Prof. Dr DDr h.c. Michael Lang is the head of the Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business) and academic director of both the LLM Program in International Tax Law and the Doctoral Program in International Business Taxation (DIBT) of this university. He is president of the Austrian Branch of the International Fiscal Association (IFA). He has been a visiting professor at Georgetown University, New York University, Sorbonne, Bocconi, Peking University (PKU), University of New South Wales (Sydney), and other universities.