The Position
- Manages and executes the global Transfer Pricing function and reports to the Director, Transfer Pricing and U.S. Tax Controversy. Analyzes global transfer pricing results, coordinates transfer pricing documentation, ensures compliance with transfer pricing policies, and drives data automation.
Responsibilities
- Prepare segmented P&L statements, expense allocations, and ad-hoc analytical models using technology/tools.
- Maintain key transfer pricing documents (e.g., BEPS Action 13 documentation, intercompany agreements, cost allocations).
- Oversee outside providers to prepare contemporaneous transfer pricing documentation meeting country-specific requirements.
- Monitor compliance with transfer pricing targets and advise on required adjustments.
- Prepare quarterly/annual ASC 740-compliant transfer pricing data modules.
- Review US and non-US transfer pricing rule compliance.
- Support Tax and Finance policy implementation involving systems and business processes.
- Assist Tax Accounting on interim/annual tax provision and reporting.
- Perform functional/financial/economic analyses for intercompany transactions (including financing); support IP financial valuation models.
- Support audit defense and tax controversy (respond to tax authority inquiries).
- Analyze financial supply chain issues and transfer price accuracy; monitor legislative changes affecting TP positions/compliance.
Qualifications & Skills (Required/Plus)
- Bachelorโs in economics, finance, accounting, business, or related.
- MBA/JD/LLM/Masterโs/PhD preferred.
- 6+ years public accounting and/or corporate transfer pricing or international tax experience.
- Data analytics/model automation/visualization tools (e.g., Business Objects, Alteryx, Power BI, Tableau, Power Automate).
- Experience with AI/automation; knowledge of transfer pricing, international tax, accounting.
- Familiarity with functional analysis interviews, TP documentation coordination, and tax planning (e.g., IP transfers/principal models).
- Tax controversy/dispute resolution experience (audits, APAs).
- ERP/EPM experience (e.g., SAP/S4 HANA, Hyperion, Oracle).
- Strong project management; quantitative and communication skills.