Transfer Pricing Manager

Description

• Advise on post-acquisition integration of entities, IP, and intercompany arrangements
• Develop defensible narratives that articulate functional analysis, business rationale and economic justification for intercompany arrangements
• Collaborate with external advisers on audit strategy and coordinate cross functional input for audit responses
• Help develop long-term tax strategies aligned with global expansion and business transformation
• Provide strategic modeling and scenario analysis to guide leadership decisions on cross-border structures and tax implications
• Prepare or support legal entity and IP valuations
• Develop governance models for consistent intercompany documentation across jurisdictions
• Draft, design, and maintain intercompany agreements to ensure alignment with transfer pricing policies, operational substance, and evolving business needs
• Lead or assist with transfer pricing audit support, serving as a primary point of contact for inquiries related to intercompany transactions, valuations and policies
• Draft clear and technically robust responses to tax authority questions, information requests and position papers
• Maintain awareness of global regulatory changes, including OECD BEPS and Pillar Two, and assess their implications for planning
• Assess the transfer pricing and international tax implications of new markets, product launches, business reorganizations, and M&A
• Assist with the development of global transfer pricing strategies
• Evaluate and advise on IP migration, IP ownership models, DEMPE functions, and R&D structuring
• Conduct economic analyses to support planning initiatives, entity migrations, or shifts in IP ownership
• Coordinate with external valuation firms when necessary and review technical valuation reports for accuracy and alignment with tax strategy
• Partner closely with Legal, Finance, and Accounting to ensure agreements reflect accurate functional and economic analyses

Requirements

• Strong analytical, project management and organizational skills.
• Strong communication and interpersonal skills.
• 5–8 years of transfer pricing experience, preferably in a multinational software or technology company or a Big Four firm.
• Solid understanding of the US transfer pricing regulations, the OECD Guidelines, and the BEPS Action Plans.
• Ability to meet project deadlines with a focus on details.
• Ability to work effectively in a fast paced, rapidly changing environment.
• Bachelor's degree required. JD or Master’s degree, or other post-graduate qualification or professional certification (CA, CPA, CFA) preferred.
• Ability to perform financial / economic analyses.
• Excellent written and verbal communication skills
• Ability to work collaboratively and to operate cross-functionally.

Benefits

Training + Development

Interview process

Visa Sponsorship

Security clearance