Transfer Pricing Manager

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Circle is a financial technology company at the epicenter of the emerging internet of money, where value can finally travel like other digital data—globally, nearly instantly and less expensively than legacy settlement systems. This ground‑breaking new internet layer opens up previously unimaginable possibilities for payments, commerce and markets that can help raise global economic prosperity and enhance inclusion. Our infrastructure—including USDC, a blockchain‑based dollar—helps businesses, institutions and developers harness these breakthroughs and capitalize on this major turning point in the evolution of money and technology.

Circle is committed to visibility and stability in everything we do. As we grow as an organization, we’re expanding into some of the world's strongest jurisdictions. Speed and efficiency are motivators for our success and our employees live by our company values:
High Integrity, Future Forward, Multistakeholder, Mindful, and Driven by Excellence. We have built a flexible and diverse work environment where new ideas are encouraged and everyone is a stakeholder.

You’ll be responsible for the end‑to‑end operational transfer pricing (TP) lifecycle—policy design, operationalization and documentation—so our inter‑company pricing is compliant, defensible, and aligned with business reality. You will also be involved in TP planning and controversy as required. You’ll partner closely with Finance, Accounting, Treasury, Legal, and the business to keep policies current as we grow and as rules evolve.

• Embed pricing in systems and processes (e.g. Oracle, AI tools); ensure accurate charge‑outs, cost allocation bases, and inter‑company agreements (ICAs).
• Responsible for monthly operational TP including set‑up, calculations, testing, billing, journals; experience with Oracle ERP will be key.

• Own Master File, Local Files, and Country‑by‑Country Reporting (CbCR); ensure on‑time, audit‑ready packages and a clean transaction register.
• Coordinate local advisor work, translations, and statutory needs.

• Build repeatable data pipelines for TP; manage and drive further automation and analytics (Oracle, AI tools).
• Measure and improve cycle times, quality, and control effectiveness.

• Be control owner for TP operational controls: walkthroughs, test scripts, evidence, and remediation.
• Produce support packs that feed Master/Local Files and CbCR (Table 1 mapping consistent with ledgers).
• Coordinate with local advisors for statutory nuances; keep a clean PBC trail for audits.

• Assist in the design pricing for new flows, restructurings, and business launches; build robust models and benchmarking using appropriate methods (CUP, TNMM, CPM, Profit Split).
• Maintain and evolve global TP policies across all group transactions.
• Translate regulatory change into practical policy and controls.

• 8–12+ years TP experience (Big Four/consulting and/or in‑house); exposure to multi‑jurisdiction groups.
• Degree in Tax/Accounting/Economics/Finance; advanced degree or tax qualification preferred.
• Deep knowledge of OECD Guidelines, BEPS (incl. Actions 8–10 & 13) and key local rules (e.g., US 482/EU frameworks).
• Hands‑on with benchmarking, financial modeling, and documentation for services, and IP/DEMPE analyses.
• Comfortable operationalizing policy in ERP environments (Oracle), and partnering with Accounting on close/true‑ups.
• Excellent stakeholder management and clear written/oral communication; able to explain TP to non‑tax leaders.
• Project management chops: plan, prioritize, and deliver across multiple countries and deadlines.
• Experience with Oracle Fusion and PCM a bonus.
• Experience/familiarity with Slack, Apple MacOS and GSuite.

Circle is on a mission to create an inclusive financial future, with transparency at our core. We consider a wide variety of elements when crafting our compensation ranges and total compensation packages.

Starting pay is determined by various factors, including but not…