Design and implement transfer pricing policies and intercompany pricing frameworks in coordination with the Head of Transfer Pricing
Lead the preparation and maintenance of transfer pricing documentation, including master files, local files, and country-by-country reports across multiple jurisdictions
Draft and manage intercompany agreements in collaboration with Legal
Support the transfer pricing aspects of complex transactions, including M&A, restructurings, and new business initiatives
Assist in the initiation and management of Advance Pricing Agreements (APAs) and support the team through transfer pricing audits, including managing responses to tax authorities
Identify, document, and support uncertain tax positions related to transfer pricing
Build and maintain transfer pricing models and economic analyses to support pricing decisions and compliance
Support quarterly and year-end close processes related to transfer pricing
Manage relationships with external transfer pricing advisors and coordinate multi-jurisdictional engagements
Monitor developments in global transfer pricing rules, including OECD guidelines, U.S. IRC §482 regulations, and country-specific changes, and communicate implications to internal stakeholders
Collaborate with Accounting, Finance & Strategy, Legal, HR, and other departments on intercompany pricing strategies
Identify and drive process improvements and automation opportunities in transfer pricing workflows and documentation
Requirements
10+ years of transfer pricing experience, including experience in a leadership or senior individual contributor capacity
Strong, hands-on familiarity with OECD transfer pricing guidelines/initiatives and U.S. IRC §482 regulations
A degree in a relevant field, such in a law degree (JD and/or LLM) or a degree in a quantitative field, such as Economics, Finance, Accounting, Mathematics, or Statistics (advanced/graduate degrees are a plus)
Solid quantitative economic analysis skills
A reputation for being a diligent self-starter
Experience preparing or overseeing transfer pricing compliance/documentation across multiple jurisdictions
The ability to work cross-functionally and communicate effectively with both technical and non-technical stakeholders
Strong project management skills and comfort working in an ambiguous, fast-paced environment