Transfer Pricing Senior Manager; EPC Environment

Transfer Pricing Senior Manager (EPC Environment)

Location: United States, Irving, Texas

Our client is proud to design and build projects and careers. We are committed to fostering a welcoming and collaborative work environment that encourages big‑picture thinking, brings out the best in our personnel, and helps us develop innovative solutions that contribute to building a better world together. If this sounds like a culture you would like to work in, you are invited to apply for this role.

A global EPC firm is seeking a hands‑on Transfer Pricing Senior Manager to lead and support transfer pricing planning, execution, and documentation across multiple jurisdictions. This role requires a seasoned professional with strong OECD and U.S. transfer pricing knowledge, proven experience partnering with Big 4 firms, and a practical, roll‑up‑your‑sleeves mindset—someone who is detail‑driven, execution‑focused, and comfortable owning deliverables end‑to‑end.

This position supports transfer pricing policy, documentation, and operational alignment for large‑scale global EPC operating entities, partnering closely with Finance, Legal, and business leadership.

• Lead and maintain the company’s global transfer pricing policy (intercompany services, IP/royalties, cost allocations), ensuring alignment with business operations
• Oversee annual transfer pricing documentation (Master File/Local File where applicable), benchmarking support, and intercompany agreements in coordination with local legal team and external advisors
• Oversee implementation and monitoring of intercompany pricing and true‑ups, including calculations, and coordination with both project and corporate accounting for timely bookings
• Serve as primary liaison with external firms on transfer pricing planning, documentation, audits, and controversy support
• Advise on transfer pricing implications for global EPC projects, joint ventures, and cross‑border project structures (including permanent establishment considerations where relevant)
• Partner with Tax Accounting on ASC 740 transfer pricing‑related reserves, uncertain tax positions, and effective tax rate impacts
• Provide operational guidance to Finance and business teams on intercompany billing, cost allocations, and data requirements to support documentation and audit readiness
• Support transfer pricing audits and inquiries (IRS, foreign tax authorities), including responses to information requests, position papers, and coordination with counsel/advisors
• Maintain transfer pricing controls, calendars, and documentation standards, drive process improvements and consistency across jurisdictions

• 7+ years of progressive transfer pricing experience (in‑house and/or public accounting)
• Proven experience partnering with Big 4 firms or outside legal counsel on transfer pricing documentation, planning, and/or controversy matters
• Experience in engineering, construction, EPC, or project‑based global organizations, with an understanding of cost structures and project execution models a strong plus
• Experience in pulling and analyzing detailed information from financial accounting systems
• Strong project management skills, attention to detail, and ability to lead complex work streams with minimal oversight

• Experience supporting global operations across multiple jurisdictions, including OECD‑aligned documentation requirements
• Knowledge of cross‑border EPC project structures, intercompany service models, and cost allocation methodologies
• Ability to thrive in a fast‑paced, deadline‑driven environment while balancing strategic advisory and hands‑on execution
• Bachelor’s degree in tax or accounting and/or CPA preferred
• Experience in U.S. International taxation a plus.

• Global Transfer Pricing Policy, Planning & Governance
• Transfer Pricing Documentation (Master File/Local File) & Audit Defense Support
• EPC / Project‑Based Business Understanding & Cost Allocation Methods
• Strong Excel & financial systems skills; ability to translate data into defensible analyses
• Strong stakeholder management across Tax, Finance, Legal, and business leadership
• Hands‑on, ownership mentality…