Transfer Pricing Manager @ Allison Transmission

Accounting (1)

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Building cities. Driving commerce. Fueling Progress. For over 100 years, Allison has powered the vehicles and technology that move our world forward.

What powers us? Our employees. From the first person hired by James Allison in 1915 to the thousands across the globe who work for Allison today, we're driving progress everywhere because we employ top talent worldwide. In both the Allison Transmission and Allison Off-Highway Drive and Motion Systems business units, our team strives to Improve the Way the World Works.

Learn more about this role and how you can begin driving your career forward!

Benefits:

The below list features some of the benefits currently available. Eligibility may be subject to the terms and conditions of governing documents and available benefits may be subject to change at the company’s discretion.

Choice of medical plans with prescription coverage
Employer HSA contribution
Dental & Vision Insurance
Paid Parental Leave
Short & Long-Term Disability
Other voluntary benefits including: Critical Illness, Hospital Indemnity, Identity Theft Protection and Pet Insurance
401K with generous Company match & contribution
Accrued Paid Time Off
12 Paid Holidays + 1 Floating Holiday
Robust employee wellness program
Tuition assistance program

Job Description:

The Transfer Pricing Manager is a key role within Allison’s tax team that includes responsibilities responsible for designing, implementing, and maintaining Allison’s global transfer pricing framework. This includes implementing the transfer pricing, coordinating global documentation, managing TP audits and controversy, and partnering closely with Finance, Tax, Legal, and Business units to ensure that intercompany transactions are aligned with both business objectives and local regulatory requirements.

Key Responsibilities:

Transfer Pricing Strategy & Planning

· Develop and refine transfer pricing policies consistent with the group’s operating model, value chain, and business strategy.

· Evaluate and advise on tax and transfer pricing implications of business restructurings, supply chain changes, and new business initiatives (e.g., new products, manufacturing locations, distribution models).

· Provide technical transfer pricing insights to senior management to support informed decision-making.

Operational Implementation & Governance

· Support the design and implementation of intercompany pricing models for tangible goods, services, IP, and financing arrangements.

· Translate transfer pricing policies into clear, practical guidance and processes for Finance, Accounting, and Business teams.

· Work with regional controllers and shared service centers to ensure accurate calculation, booking, and monitoring of intercompany charges (e.g., cost allocations, royalties, service fees, mark-ups).

· Develop and maintain robust governance, including intercompany agreements, documentation standards, and control frameworks.

· Monitor actual margins and results versus policy targets and recommend adjustments as needed.

Documentation & Compliance

· Coordination of global transfer pricing documentation, including Master File and Local Files, and Country-by-Country Reporting (CbCR).

· Oversee preparation and support for local transfer pricing forms, disclosures, and related tax return reporting.

Audit Management & Controversy

· Assist controllers for transfer pricing inquiries from tax authorities across jurisdictions.

· Manage transfer pricing audits, information requests, and dispute resolution, working with external advisors where necessary.

· Assess and quantify transfer pricing risks and exposures; recommend and implement mitigation strategies.

· Support Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP) processes when appropriate.

Business Partnering & Cross-Functional Collaboration

· Collaborate with Treasury, Legal, Operations, and Commercial teams on new intercompany arrangements and business initiatives.

· Provide training and guidance to Finance and Tax colleagues on transfer pricing policies, changes in regulations, and practical application.

· Communicate complex transfer pricing concepts in a clear, business-oriented manner to non-tax stakeholders.

· Assess impacts of regulatory changes on Allison Transmission’s transfer pricing model and recommend proactive responses

Key Performance Measures:

Effective/timely management of compliance process
Effective/timely communication with internal/external customers
Problem solving ability and desire to improve current processes

Qualifications:

Bachelor’s degree in Accounting, Finance, Economics, Business, or related field.

· Professional qualification such as CPA, CTA, or equivalent, or advanced degree in Tax, Economics, or Finance.

· Experience within the manufacturing, automotive, or industrial sectors.

· Familiarity with ERP systems (e.g., SAP, Oracle) and tax/TP software tools

Experience:

5 to 8+ years of tax experience with at least 3+ of dedicated transfer pricing experience, ideally with a combination of Big Four/consulting and in-house multinational exposure.

· Strong technical knowledge of U.S. transfer pricing regulation, OECD Guidelines and key transfer pricing concepts (e.g., functional analysis, comparability, method selection, DEMPE, value chain analysis).

· Hands-on experience reviewing transfer pricing documentation (Master File/Local File) and managing multi-jurisdiction compliance.

· Proven experience with transfer pricing planning and implementation of intercompany policies across multiple entities and jurisdictions.

· Demonstrated experience handling tax authority queries or audits in the transfer pricing area.

· Advanced Excel skills and comfort working with financial data and modeling.

· Excellent written and verbal communication skills, with the ability to present complex issues clearly to senior management.

Allison Transmission is an equal opportunity employer. We have opportunities for all qualified applicants regardless of age, race, color, sex, religion, creed, national origin, disability, sexual orientation, gender identity/expression or veteran status.

If you are an individual with a disability or a disabled veteran requiring assistance and/or reasonable accommodations reviewing any of the careers information, please contact us at [email protected].

Please note that Allison Transmission will make an offer of employment only to individuals who have applied for a position using our official application. Be on alert for possible fraudulent offers of employment. Allison Transmission will not solicit money or banking information from applicants.

Transfer Pricing Manager

Allison Transmission

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