Ryann Thomas

Ryann Thomas

Partner, PwC Tax Japan

Transfer Pricing Services


Ryann Thomas is a Partner in the Transfer Pricing Consulting Group of PwC Tax Japan.

Since she joined the firm in mid-2001, Ms. Thomas has worked exclusively in the transfer pricing area, assisting both inbound and outbound multinational corporations with transfer pricing audit defense, advance pricing agreements, documentation and economic analyses, and risk assessments.

During her career, Ms. Thomas has been involved with clients from a wide variety of industries, including financial services, luxury goods, food and beverages, life sciences, and e-commerce.

Prior to coming to Japan, Ms. Thomas worked as a Barrister and Solicitor in commercial and private litigation in New Zealand.

Contact Form

Contact details


  • 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

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

Professional Vision

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, etc.