Description:
We are seeking a highly-motivated experienced individual to join our global tax team to assist in reviewing, thinking, and planning around new global developments in transfer pricing. This role focuses on forward-looking strategy, cross- border structuring and high impact advisory support rather than routine compliance. You will play a critical role in shaping our global tax structure and supporting strategic initiatives across international markets.
The Transfer Pricing Manager will report to the Transfer Pricing Director and will be a member of a worldwide finance team that strives to be best-in-class. This position can be 100% remote in the U.S., Canada, or EMEA.
Responsibilities
Strategic Planning & Advisory
- Assist with the development of global transfer pricing strategies
- Assess the transfer pricing and international tax implications of new markets, product launches, business reorganizations, and M&A
- Advise on post-acquisition integration of entities, IP, and intercompany arrangements
- Provide strategic modeling and scenario analysis to guide leadership decisions on cross-border structures and tax implications
- Evaluate and advise on IP migration, IP ownership models, DEMPE functions, and R&D structuring
- Maintain awareness of global regulatory changes, including OECD BEPS and Pillar Two, and assess their implications for planning
- Help develop long-term tax strategies aligned with global expansion and business transformation
Intercompany Legal Architecture
- Draft, design, and maintain intercompany agreements to ensure alignment with transfer pricing policies, operational substance, and evolving business needs
- Partner closely with Legal, Finance, and Accounting to ensure agreements reflect accurate functional and economic analyses
- Develop governance models for consistent intercompany documentation across jurisdictions
Valuation & Economic Analysis
- Prepare or support legal entity and IP valuations
- Coordinate with external valuation firms when necessary and review technical valuation reports for accuracy and alignment with tax strategy
- Conduct economic analyses to support planning initiatives, entity migrations, or shifts in IP ownership
Audit Strategy & Defense
- 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
- 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
Qualifications
- Bachelor's degree required. JD or Master’s degree, or other post-graduate qualification or professional certification (CA, CPA, CFA) preferred.
- 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.
- Strong communication and interpersonal skills.
- Excellent written and verbal communication skills
- Ability to meet project deadlines with a focus on details.
- Strong analytical, project management and organizational skills.
- Ability to work effectively in a fast paced, rapidly changing environment.
- A self-starter, motivated and able to work independently.
- Ability to work collaboratively and to operate cross-functionally.
- Ability to perform financial / economic analyses.