Transfer Pricing Senior Manager

Our client is a truly global organisation within the technology sector. They are looking to appoint a senior manager - Transfer Pricing into a highly visible role across the organisation. Reporting into a Global Head of TP you will be given the autonomy to manage your time to deliver on strategic projects across all facets of transfer pricing

* This is a fantastic opportunity for a technical specialist to lead on transfer pricing for a complex group. The Transfer Pricing Manager will partner with a cross-border tax team to design and implement a robust strategy, manage risk and play a leading role in key transfer pricing projects and structuring initiatives.
* Manage all aspects of transfer pricing projects including planning of structure, fact gathering, functional and economic analyses and implementation in collaboration with other tax team members and internal stakeholders. Provide intercompany solutions tailored to project and business operational needs.
* Preparation and/or review transfer pricing documentation and benchmarking studies for worldwide group, identifying and implementing process improvements
* Understand the trend of worldwide transfer pricing legislation and adapt the group transfer pricing position accordingly.
* Manage the relationships and follow up of tax authority audits with respect to transfer pricing mattes, ensuring robust defence strategies and take a lead in negotiations.
* Take a leading role in preparing the group for BEPS country-by-country reporting.

Candidate requirements :

* The candidate will possess a Bachelor's Degree (or higher) in Economics, Finance, Business, Law or Accounting with ACA/CTA/ACCA/CPA or legal qualifications preferred.
* The candidate must be very strong technically, with a minimum 7 years (approximately 4 years PQE) of transfer pricing experience or a combination of international tax and transfer pricing.The candidate will have a Big 4 background (or combined Big 4 and global blue chip background), and will have had extensive experience in preparing transfer pricing reports including performing analysis using all specified transfer pricing methods.
* Relevant transfer pricing advisory experience will include IP structuring, intercompany financing, performing DCF valuations, ETR modelling, drafting intercompany agreements, as well as supporting international tax planning and compliance processes.
* The candidate will have a firm grounding in the UK, US, or other EU country tax regime, as well as familiarity with key international tax principles, including application of treaties and CFC legislation.
* Practical knowledge and extensive prior application of OECD Transfer Pricing Guidelines is required. Experience with IRS transfer pricing regulations would be advantageous.
* The candidate must have a proven ability to solve complex transfer pricing issues and take ownership in delivering solutions. The candidate must be able to effectively build relationships with and advise internal stakeholders and collaborate in delivering pragmatic solutions.