Since joining the firm in 2001, Ryann has worked in international tax services for multinational enterprises, including many years dedicated to transfer pricing. Her clients are primarily foreign-headquartered companies conducting inbound business to Japan, although she also works with large Japanese multinational corporations on global projects. Ryann has been involved in a variety of projects involving corporate tax and transfer pricing audits, APAs, business restructurings, and transformations. She also has experience in dealing with permanent establishments and the attribution of profits thereto, including managing potential tax risks arising from offshore principal structures.
Prior to coming to Japan, Ryann worked as a Barrister and Solicitor in commercial and private litigation in New Zealand.
Project Results and Achievements
- Bilateral APA for global trading, involving a return on capital
- Successful conclusion of unilateral APAs for clients without the option of the bilateral APA process
- Provision of audit defence assistance for extensive and detailed transfer pricing audits
- Provision of audit defence assistance for a number of corporate tax audits where donation challenges were raised on transfer pricing matters
Publications / Seminars / Other Activities
- Clarifying the Rules: Sustainable transfer pricing in the financial services sector (editor)
- Arbitration under the New Japan-Netherlands Tax Treaty, Bulletin for International Taxation, April/May 2011, p223
- A fresh look at the Japan-US bilateral relationship, BNA Transfer Pricing International Journal, June 2013, p1
- National Tax Agency transfer pricing update – update on audit procedures, BNA Transfer Pricing International Journal, April 2013, p35
My vision is for PwC Tax Japan to be the preferred Japan tax advisor for Japanese and international business, as well as a preferred employer for young Japanese men and women. I would like to achieve this through the development of a highly skilled and professional workforce that is diverse in all aspects of gender, race, age, etc.