Ireland

PwC Ireland

1 Spencer Dock

North Wall Quay

Dublin 1

Ireland

Tel: +353 (0) 1 792 8704

Mobile: +353 (0) 87 929 4747

Email: gavan.ryle@ie.pwc.com

Website: pwc.com/taxcontroversy

Gavan Ryle is the partner leading the transfer pricing practice of PwC Ireland. He has been with the firm since 1993, and worked for five years with the transfer pricing group in the Sydney office of PwC between 1997 and 2002. Since returning to the Dublin office in 2002, Gavan established a transfer pricing practice in the Irish firm and six years later was admitted as a partner in 2008. He now leads a team of 20 professionals working full time on transfer pricing planning, documentation and defence projects out of the Dublin office.

The PwC Ireland transfer pricing practice was well established before the introduction of Ireland's broad-based transfer pricing rules in 2011. From Gavan's experience in dealing with transfer pricing controversy cases in Australia, he is well positioned to assist Irish companies involved in the Transfer Pricing Compliance Review Programme implemented by the Irish tax authorities in 2013 and their transfer pricing audits which began in 2015.

Gavan also has extensive experience in advising on mutual agreement procedures (MAPs) and advance pricing agreements (APAs). He has assisted many multinational companies with dispute resolution and competent authority proceedings, and in particular has advised multinationals whose Irish operations have been at the receiving end of transfer pricing adjustments in overseas territories. Gavan works closely with the competent authority team of the Irish tax authorities to resolve the double taxation arising, minimise the adjustment amount and secure the repayment of Irish tax.

He has also been involved in several APA negotiations, advising both Irish headquartered multinationals and multinationals with Irish operations on the pros and cons of seeking an APA, holding preliminary discussions with the Irish tax authorities, preparing APA submission documents and supporting multinationals through the negotiation process.