Rachel Ney

Rachel is a principal in the transfer pricing practice and leader of the national advance pricing agreement (APA) and mutual agreement procedure (MAP) practice. Prior to joining Deloitte, she spent 13 years at the Internal Revenue Service, including a decade with the Advance Pricing and Mutual Agreement (APMA) Program.

Rachel has served as a negotiator and strategist in APA and MAP cases with tax authorities from Germany, France, Italy, Ireland, Luxembourg, Austria, Finland, China, Canada, and other key treaty partners. Throughout her tenure, Rachel has led multiple APMA teams, providing technical direction and strategic guidance on complex transfer pricing and double taxation matters spanning more than 20 jurisdictions.