Paul Mulvihill is a Partner with Ernst & Young's International Tax Services – Transfer Pricing practice in Canada. Paul is also EY Canada's Transfer Pricing Controversy Leader and a member of the firm's Global Transfer Pricing Controversy Network where he specializes in assisting multinational enterprises resolve their international tax disputes and deal with the Canada Revenue Agency (CRA) at the audit, appeals, and treaty relief levels. Paul also has wide-ranging experience in transfer pricing planning, policy, and compliance.
Prior to joining EY, Paul was with the CRA's International Tax Directorate in Ottawa where he held progressively senior positions in the area of transfer pricing and competent authority services. There he gained extensive experience in international tax controversy while managing Advance Pricing Arrangements (APAs), Mutual Agreement Procedure cases, and developing policies on substantive transfer pricing and cross-border tax issues. Given his role as primary drafter of the CRA's Program Development Strategy on APAs and as a primary contributor to the CRA's Guidance on Competent Authority Assistance under Canada's Tax Conventions, Paul was considered one of the leading government authorities on tax policy related to the resolution of international tax disputes.
Paul spent the last two of his fifteen years in public service on leave to work on international tax policy as the Advisor on Dispute Resolution at the OECD's Centre for Tax Policy and Administration in Paris. Paul was responsible for support drafting and work on the Manual on Effective Mutual Agreement Procedures and the development of the arbitration provisions in the OECD Model Tax Convention on Income and Capital and its Commentary as well as other matters related to transfer pricing.
Over the past 16 years, Paul has spoken at numerous international tax conferences on the topics of transfer pricing and the resolution of international tax disputes. He has authored a number of articles on transfer pricing controversy, APAs, and arbitration provisions within tax conventions to resolve double taxation.
Paul is a member of the International Fiscal Association, the Canadian Tax Foundation, and has been nominated to appear in Legal Media's annual Guide to the World's Leading Transfer Pricing Advisors since 2007. He is a graduate of the University of Alberta and the University of Windsor and holds a BSc in Mathematics and an MBA with a specialization in Finance.