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Raffaele Petruzzi

Dr. Raffaele Petruzzi, LL.M. 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) and an international tax advisor specializing in international tax and transfer pricing at Baker McKenzie, where he is part of the EMEA Transfer Pricing Group and he is the Head of the Austria Transfer Pricing Group. Raffaele has gained extensive experience in dealing with topics related to international tax and transfer pricing for many years, both from a professional and an academic side. From the professional side, he regularly advises clients across numerous industries on specific topics (e.g. international tax and transfer pricing issues related to services, permanent establishments, financing, business restructuring, intangibles, indirect taxes, valuation of companies and intangible assets), international tax and transfer pricing risk management and compliance, optimization of international tax structures, implementation of mechanisms of dispute avoidance (e.g. rulings and APAs) and dispute resolution (e.g. MAPs and arbitrations), and tax audit defense. From the academic side, he is a frequent speaker in international conferences and lecturer of numerous courses all over the world, as well as author of many publications. Moreover, he regularly cooperates with professionals in advisory, the business community, governments and international organizations (e.g. OECD, United Nations, World Bank Group, International Monetary Fund, and European Commission). Inter alia, he regularly provides assistance on tax policy issues, capacity building for tax administrations, and advising governments on projects related to fight against tax evasion. Finally, amongst others, he is a member of the United Nations Subcommittee on Transfer Pricing, of the International Fiscal Association (IFA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a Ph.D. in International Business Taxation at WU, an LL.M. in International Tax Law at WU, and an M.Sc. in Business Administration and Law at Bocconi University.

Transfer pricing is one of the most relevant and challenging topics in the international tax environment. The increasing global trade and the role of multinational enterprises in the global economy have boosted the importance of this topic. This lecture will provide the students with the fundamental tools to understand transfer pricing topics and the arm’s length principle, both from a legal and an economic perspective. The theoretical analysis will be supported by examples and cases coming from practice. Particular focus will be given to the relevance of the comparability analysis in light of the new approach envisaged by the BEPS Report on Actions 8, 9 and 10 and an overview on the selection of the most appropriate transfer pricing methods.

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