Director – Transfer Pricing

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Why This Role

The Director of Transfer Pricing is responsible for leading the company's global transfer pricing strategy, policy development, operational implementation, documentation, controversy management, and planning initiatives. This role serves as the primary transfer pricing leader for the enterprise, ensuring compliance with global transfer pricing regulations while supporting the company's business and tax objectives.

The Director will partner closely with Finance, Supply Chain, Treasury, Legal, Business Leadership, Tax Planning, Tax Reporting, and Tax Compliance teams to develop and maintain robust transfer pricing policies aligned with the organization's operating model, value chain, and global business strategy. The role also provides strategic guidance on acquisitions, divestitures, restructurings, intellectual property planning, supply chain transformations, and intercompany financing arrangements. It serves as the primary transfer pricing leader for the enterprise, ensuring compliance with global transfer pricing regulations while supporting the company's business and tax objectives.

What You'll Own

Transfer Pricing Strategy & Planning 

• Develop and execute the company's global transfer pricing strategy to support business growth, operational efficiency, and effective tax management. 
• Design, implement, and maintain transfer pricing policies for intercompany transactions involving tangible goods, services, intellectual property, financing arrangements, and cost-sharing agreements. 
• Evaluate transfer pricing implications of mergers, acquisitions, divestitures, internal restructurings, and supply chain transformations. 
• Support tax planning initiatives involving intellectual property ownership, principal structures, commissionaire arrangements, contract manufacturing, shared service centers, and intercompany financing. 
• Monitor global tax developments, including OECD guidance, Pillar Two initiatives, local country regulations, and emerging transfer pricing trends. 

Operational Transfer Pricing 

• Oversee the annual transfer pricing process, including policy implementation, intercompany pricing calculations, true-ups, and monitoring of operational results. 
• Partner with Finance, Controllership, and Shared Service Centers to ensure transfer pricing policies are accurately reflected in business processes, ERP systems, and financial reporting. 
• Develop and maintain standardized transfer pricing models and governance procedures. 
• Drive process improvements, automation initiatives, and data analytics capabilities within the transfer pricing function. 

Documentation & Compliance 

• Lead preparation and review of global transfer pricing documentation, including Master Files, Local Files, benchmarking studies, and country-specific documentation requirements
• Coordinate with regional tax teams and external advisors to ensure timely compliance with local transfer pricing regulations. 
• Establish and maintain documentation standards, controls, and governance processes supporting the company's transfer pricing positions. 
• Collaborate with Tax Compliance teams to ensure transfer pricing adjustments are appropriately reflected in tax returns and related filings. 

Transfer Pricing Controversy & Audit Defense 

• Lead transfer pricing audit defense strategies globally. 
• Manage interactions with tax authorities regarding transfer pricing examinations, inquiries, and information requests. 
• Coordinate responses to transfer pricing controversies and support dispute resolution efforts. 
• Evaluate opportunities for Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), and other dispute avoidance mechanisms. 
• Maintain audit-ready documentation and technical support for transfer pricing positions. 

Financial Reporting & Risk Management 

• Partner with Tax Accounting and Reporting to assess transfer pricing impacts on ASC 740 tax provisions, uncertain tax positions, and financial statement disclosures. 
• Evaluate transfer pricing risks and provide recommendations to senior leadership regarding risk mitigation and governance. 
• Assist with forecasting effective tax rate and cash tax implications associated with transfer pricing matters. 
• Support internal and external audit activities related to transfer pricing. 

Leadership & Stakeholder Management 

• Serve as the company's principal transfer pricing subject matter expert. 
• Build and lead a high-performing global transfer pricing team. 
• Manage relationships with external advisors, economists, and benchmarking providers. 
• Present transfer pricing strategies, risks, and opportunities to senior leadership, including tax and finance executives. 

What You Bring

• Bachelor's Degree in Accounting, Finance, Economics, Law, Tax, or related field. 
• Advanced degree preferred, Master of Arts in Economics, Master of Science in Economics,  PhD in Economics. or JD/LL.M
• 8+ years of progressive transfer pricing experience in a multinational corporation, Big Four accounting firm, economics consulting firm, or combination thereof. 
• Deep technical knowledge of OECD Transfer Pricing Guidelines and global transfer pricing regulations. 
• Significant experience designing and implementing transfer pricing policies across multiple jurisdictions. 
• Experience managing global transfer pricing documentation programs and transfer pricing audits. 
• Strong understanding of international tax concepts, including Pillar Two, BEPS initiatives, Subpart F, GILTI, foreign tax credits, and withholding taxes. 
• Demonstrated experience supporting complex business transformations, acquisitions, divestitures, and supply chain restructurings. 
• Strong analytical, quantitative, and financial modeling capabilities. 
• Excellent written and verbal communication skills with the ability to explain complex technical matters to senior business leaders. 

Nice to Have

• CPA, Chartered Accountant, Economist, or similar professional credential. 

• Experience leading negotiations related to APAs, MAPs, or large transfer pricing controversies. 

• Experience supporting public-company financial reporting and ASC 740 processes. 

• Familiarity with tax technology platforms, ERP systems, and data analytics tools. 

• Global people leadership experience across multiple regions. 

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