Sr. Transfer Pricing Manager

Empowering people, creating technology.

Responsibilities :

• Collaborate with North American business group leaders and global transfer pricing team to co-develop transfer pricing strategies, objectives, and policies for the North America Region (aligned with global initiatives)
• Educate business group controllers about transfer pricing considerations and best practices
• Lead research and prepare expert opinions on a broad range of transfer pricing and international tax matters, including cross-border transactions
• Develop, implement and document BEPS-compliant transfer pricing systems to identify, ringfence, and proactively implement measures to mitigate transfer pricing risk
• Oversee the timely and accurate completion of transfer pricing documentation (i.e. local and master files) and adhere to regulatory requirements (i.

e. statutory notifications and declarations) for US and Canadian operations

• Oversee outside transfer pricing service providers for Mexican and Costa Rican affiliates and support local tax team with transfer pricing matters
• Summarize status of local file documentation, quantify potential risks and recommend mitigating strategies
• Engage with outside service providers for transfer pricing technical support, benchmarking studies, and local file preparation assistance when necessary
• Team with business group controllers to drive proper accounting and periodic monitoring of operating margins and I / C pricing adjustments when necessary
• Collaborate with legal, tax, and global transfer pricing teams to proactively address transfer pricing audits and controversy
• Training and co-oversight of shared service center team assisting with preparation of routine local files
• Support US and Canadian tax compliance reporting related to transfer pricing, including but not limited to Form 5472, T-106, CbC and similar Pillar 2 intercompany transaction reporting requirements
• Participate in the preparation of intra-group contracts where transfer pricing arrangements are particularly relevant
• Support in matters relating to the assessment, declaration and taxation of permanent establishments
• Review double tax-treaties between the US and other jurisdictions and determine the applicability of such treaty on a transfer pricing matter / transaction
• Support the regional year-end tax provision process during the annual financial statement close

Qualifications :

• Bachelor’s degree in accounting and a master’s degree in accounting, finance, economics, or business required.
• 8+ years of combined transfer pricing and international tax experience from a national or regional public accounting firm, or fortune 500 company
• Executive presence - comfortable reporting to global and regional CFOs and business leaders, while still communicative and open-minded at all reporting levels
• Combination of large public accounting experience is a must; this coupled with large industry experience would profile the ideal candidate.
• Familiarity transfer pricing reporting tool or similar platforms preferred (currently using PWC's global Doc; previously Thompson Reuters transfer pricing platform)
• Transfer pricing regulatory experience using BNA / RIA / IBFD or similar databases.
• Experience with Hyperion Financial Management (HFM) is ideal.
• Excellent communication (both written and oral) and interpersonal skills
• Strong analytical and data interpretation skills
• Experience teaming with various business functional areas on project.
• Experience and proven practical knowledge of MS Office, specifically MS Excel.
• Experience working with manufacturing companies.
• Familiarity with US or Canadian corporate income tax a plus
30+ days ago