Transfer Pricing Manager

Person Specification

• Proven skills and experience in transfer pricing gained in practice and/or industry
• A good understanding of the OECD Transfer Pricing Guidelines
• Able to explain complex issues in a way non-tax specialists can clearly understand
• Up-to-date technical skills and experience, across a broad range of businesses
• Ability to manage work within budgets and deadlines
• Good report writing skills (including Master Files, Local Files and specialist input into due diligence and tax audit reports)

Transfer pricing projects can involve:

• Planning and design of transfer pricing policies for all transaction types (including tangible goods, services, intellectual property and financing) covering various business operating models
• Preparation and review of transfer pricing documentation including benchmarking studies e.g. Master Files, Local Files and Country-by-Country Reporting
• Review and guidance on implementation of transfer pricing policies e.g. financial and operational testing of policies, comment on agreements prepared by legal advisors
• Review of intercompany financing arrangements
• Thin capitalisation reviews
• Transfer pricing risk reviews of cross-border operations and remediation advice
• Advance Pricing Agreement and Mutual Agreement Procedure cases
• Dispute resolution with tax authorities
• Awareness of broader tax considerations of transfer pricing policies and cross-border operations e.g. withholding taxes, VAT/customs duties and permanent establishment risks

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As an employer, we are committed to ensuring the representation of people from all backgrounds regardless of their gender identity or expression, sexual orientation, race, religion, ethnicity, age, neurodiversity, disability status, or any other aspect which makes them unique. We welcome applicants from all backgrounds to apply and would encourage you to let us know if there are steps, we can take to ensure that your recruitment process enables you to present yourself in a way that makes you comfortable.