Senior Transfer Pricing Manager — Global EPC Projects

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Transfer Pricing Senior Manager (EPC Environment)

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.

Key Responsibilities

• 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

Qualifications
-Required

• 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

Preferred Skills

• 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 US International taxation a plus.

Key Skills & Attributes

• 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…