Manager – Transfer Pricing

The Manager, Transfer Pricing reports to Sr Manager, Transfer Pricing and is responsible for the application of global transfer pricing policy and governance of the Company.  We are committed to providing a technology infrastructure to enable tools and resources for process optimization. With a diverse platform of companies, our business provides opportunities for continuous growth and new challenges. 

What You’ll Do

• This role is principally responsible for the application of global transfer pricing policy, completion and review of transfer pricing documentation, oversight of operational transfer pricing results, and act as transfer pricing advisor to parts of the Company with little to no tax specialization. The Company’s operating structure is decentralized with several finance organizations and multiple ERP systems. For this reason, effective collaboration with the tax technology team and the local finance teams are required to ensure accurate and timely data is available. Conduct data analysis and perform economic and financial modeling to assist with corporate projects and fulfill international transfer pricing reporting obligations.

Your role includes the following:

• Technical Resource: This role is expected to have expertise equivalent to the job title in U.S. transfer pricing statute, regulations, and relevant court cases; the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, OECD’s Base Erosion and Profit Shifting 1.0 and 2.0 initiatives, and Country by Country Reporting requirements; transfer pricing documentation requirements, and experience with operational transfer pricing (e.g., creating segmented P&Ls, calculating TP adjustments). For all other countries, using a network of advisors, the role must monitor proposed and newly enacted legislation, regulations, rulings, and court cases which may impact to the global transfer pricing policy of the Company.
• Collaborative Planning: Collaboration with the global tax organization, corporate finance and accounting, local controllers, and global trade to address multi-faceted impacts from business changes or tax planning. 
• Annual Documentation / Valuation: Facilitate fact-gathering and preparation of transfer pricing documentation and legal entity valuations by external advisors. Be an active participant in the process to develop an expert understanding of the global operations in the Company. Review with local controllers the facts presented in documentation to ensure alignment with the facts of the business.
• Operational Transfer Pricing: Apply the global transfer pricing policy of the company, which requires periodic review to modify or update as needed to remain in global compliance. Ensure intercompany agreements, transaction flows, transaction types, and ERP prices are consistent with policy and are supportable under audit. This role will assist in the design of processes and Excel workbooks required for the business to prepare quarterly transfer pricing segmented P&Ls to test the separate functions within a single legal entity. To the extent transfer pricing has not remained within policy, co-ordinate with the local finance, global customs/trade, and global tax organization to ensure appropriate TP adjustments are implemented and booked. 
• US GAAP Provision and various foreign tax return support: Prepare support for intercompany transaction volumes as required by various regional jurisdictions such as Canadian T106/T1134. Support quarterly and annual tax provision processes, including ASC740 reserve analysis and assist with TP forecast reviews.
• Process Optimization: Drive standardization and automation for forecasted segmented P&Ls, data gathering for TP documentation, and use of Workiva for generating TP documentation reports. Ensure alignment with tax reporting processes and broader finance technology strategies.
• Tax Audits: Support tax controversy and audit management of transfer pricing inquiries.
• Organizational Stakeholders: Develop and maintain collaborative relationships throughout the corporate organization, including those responsible for financial reporting and forecasting.

We believe our tax team thrives in our environment where individuals can actively engage in projects to fully utilize our tax attributes and integrate new businesses into our processes and corporate structure. With that in mind – in addition to your contributions to our global tax operations, you will:

• Grow your subject matter expertise through research and analysis to our ever-evolving business
• Actively participate in projects to continue our investments in tax technology tools
• Be supported in efforts to continue your training, staying current in tax developments, and establishing yourself in the tax community

Qualifications & Certifications

• Bachelor’s degree required, preferably in finance, economics, accounting or related field
• Advanced degree or certification such as CPA, CFA or MBA, preferred
• 5+ years of progressive corporate or public accounting experience in income tax, including progressive experience in transfer pricing for multi-national corporations.

Skills & Competencies

• Experience with tax software (e.g., Corptax), MSFT Office Suite, efficiency tools (e.g., Power BI Platform, Alteryx), and tools for consolidation and reporting (e.g., OneStream, Workiva).
• Knowledge of overall workflow of accounting within ERP systems (e.g., SAP, Oracle).
• Demonstrated ability to work with large sets of data from decentralized sources and using technology tools for data analysis and scenario planning.
• Demonstrated ability to translate complex transfer pricing concepts into actionable strategies.
• Demonstrated knowledge of relevant U.S. international income tax issues required for the ability to explain both U.S. international income tax issues and transfer pricing relevant for cross-border transactions.
• A strong understanding of international statutory accounts and income tax adjustments will be highly valued.
• Strong communication skills with ability to interact effectively with external advisors and finance teams throughout the organization.
• Results-oriented, technically curious, and values effective collaboration.
• Positive self-started with willingness to learn, understand the business, and readily adapt to a fast-changing business.
• High level of integrity and a commitment to upholding professional standards.
• We are tax optimizers at heart, we hope you are too!

#LI-CS23