Randall Fox leads an award winning multidisciplinary transfer pricing team based in London as well as leads the growing the international transfer pricing practice across the globe.
Randall joined DLA Piper in London in 2015 from the IRS in Washington DC, where he was an APA Team Leader and Competent Authority Analyst. He principally negotiated 50+ bilateral APAs and MAPs between the US and a number of European countries, gaining an understanding of how a number of countries approach transfer pricing issues. He generally focused on cases involving intangibles and led teams on some of the largest and most complex APAs and MAPs. Lastly, he also spent some time on secondment to the World Bank Group to help a number of different country tax administrations build their own APA and MAP programs.
Randall has a one-of-a-kind background in transfer pricing, having spent time in Big4, government (IRS APMA Program) as well as an international organization (World Bank Group) prior to joining DLA Piper. He therefore provides clients with broad perspective and the ability to provide big picture implications of policies and their impact on the US, developing countries, as well as across Europe.
Since joining DLA Piper, he has assisted a number of clients in operating model design and implementation globally, more than 25 bilateral advance pricing agreements and MAPs in 12 countries, financing structures, several large valuations of intangibles for cross border transfer, and defense-related strategies worldwide for a number of US and European-based multinationals.
As Head of the International Transfer Pricing at DLA Piper, Randall leads the cross jurisdictional transfer pricing practice outside the US.
Professional experience
Provides strategy and client representation on bilateral APAs in 12 countries, including the design and implementation of a global APA strategy for a client in the consumer goods industry
Called as an expert witness to provide written and oral testimony before a tribunal at the Netherlands Arbitration Institute on a case involving numerous transfer pricing issues
Forged new client relationships by providing innovative thinking, significant credibility based on past experience, multi-country coverage from a single point of contact, and a client first approach
As an IRS APA Team Leader, acted in a lead technical and negotiation role in a competent authority on several APAs with the potential for double taxation of more than US$1 billion
As an IRS Competent Authority Analyst, negotiated successful and principled transfer pricing MAP and APA case resolutions with foreign competent authorities in 10+ countries on a wide range of transfer pricing issues
Played a lead role in the development of APA programs and joint transfer pricing training alongside OECD in numerous developing countries while on secondment to the World Bank Group
Languages
Spanish
Education
Miami University, Master of Arts, Economics, 2005
University of Washington, Bachelor of Arts, Economics, 2002
Awards
Randall and his London-based transfer pricing team have been consistently rated a Tier 1 firm by World Transfer Pricing. In addition, the team has won International Tax Review’s UK Transfer Pricing Firm of the Year in 2017, 2018, and 2019.
Publications
Randall is a co-author of the World Bank Group Handbook on Transfer Pricing and Developing Economies.
Seminars
Keynote Speaker, Asia Tax Forum, (Singapore) 2015
Panel Participant, "Dispute Resolution and Anti-Avoidance: How taxpayers should manage disputes in 2015", Asia Tax Forum, (Singapore) 2015
Panel Participant, "TP Under Pressure: Insights from Key Policy Makers", TP Minds Transfer Pricing Americas Summit, (Miami, Florida) 2015
Panel Participant, "APAs: Latest Experience and Future Outlook", TP Minds Transfer Pricing Americas Summit, (Miami, Florida) 2015
Keynote Speaker, Global Transfer Pricing Forum, (Washington, DC) 2014
Panel Participant, "Hot Topics in Transfer Pricing", Global Transfer Pricing Forum, (Washington, DC) 2014
Prior Experience
Randall joined DLA Piper in 2015, where he has advised clients on preventing and resolving transfer pricing disputes in numerous countries. In addition, he has also been called as an expert witness in an international arbitration hearing involving numerous transfer pricing issues. He joined DLA Piper from the Internal Revenue Service (IRS) in Washington DC, where he was a Team Leader responsible for leading transfer pricing case negotiations on behalf the IRS for some of the largest cases in the history of the IRS Advance Pricing and Mutual Agreement (APMA) program.
His last two years of employment at IRS, he was seconded to the World Bank Group to assist developing country tax administrations around the world with building capacity and developing alternative dispute resolution programs. Randall developed and led training workshops on technical transfer pricing and APA matters, drafted APA guidelines for several countries, and worked directly with tax administrations, finance ministry officials as well as the OECD on numerous policy matters related to transfer pricing. Prior to his time in public service, Randall spent time as a transfer pricing advisor with both a Big4 firm and an economic consultancy firm.
