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 DoThis 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 ASC
740 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…