Director of Transfer Pricing
- Design and implement the global transfer pricing framework covering tangible goods, services, IP, and financial transactions.
- Ensure intercompany pricing aligns with business substance and value creation across supply chains.
- Monitor global tax trends (Pillar One/Two, OECD BEPS developments, and local legislation) and advise on their strategic implications.
- Maintain clear policy governance and documentation standards across all jurisdictions.
- Partner with Finance, Operations, and Legal to structure business models that achieve both commercial and tax optimization.
- Support large-scale supply chain transformations, principal structures, and shared service center models.
- Evaluate cash tax impacts and financial statement effects of transfer pricing design.
- Collaborate on intellectual property planning, cost sharing, and valuation analyses.
- Lead transfer pricing diligence, risk assessment, and structuring efforts for acquisitions and divestitures.
- Develop integration and policy harmonization strategies for newly acquired entities.
- Support IP migration and valuation projects tied to business development initiatives.
- Direct the company's global transfer pricing audit defense strategy.
- Oversee the preparation of documentation, manage regulatory inquiries, and lead engagement with tax authorities.
- Coordinate Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) requests.
- Proactively identify emerging controversy risks and establish mitigation frameworks.
- Oversee timely preparation of Master Files, Local Files, and intercompany agreements consistent with OECD and local regulations.
- Partner with tax reporting and accounting teams on FIN 48 and uncertain tax position analyses.
- Drive process automation and data quality improvements in intercompany transaction flows.
- Lead and develop a global team of transfer pricing professionals and external advisors.
- Communicate complex technical concepts clearly to executive-level stakeholders.
- Foster cross-functional collaboration with Finance, Legal, and Operations to ensure alignment between business decisions and tax policies.
- Bachelor's degree in Accounting, Economics, Finance, or a related field required.
- Advanced degree (MBA, MS Tax, JD, or PhD) preferred.
- CPA, JD, or equivalent certification a plus.
- 12-15+ years of progressive transfer pricing experience in multinational corporations or Big Four advisory firms.
- Proven leadership experience managing global teams and multi-jurisdictional operations.
- Demonstrated expertise in IP planning, cost sharing, and valuation.
- Track record managing complex audits, APAs, or MAPs.
- Experience integrating transfer pricing processes post-M&A preferred.
- Deep knowledge of OECD Guidelines, BEPS, and international tax regulations.
- Strong economic, analytical, and financial modeling skills.
- Strategic thinker with the ability to balance technical precision and practical solutions.
- Excellent communication and presentation skills.
- Skilled in tools such as Excel, Power BI, Alteryx, or similar data automation platforms.
1.1 - Executive/Senior Level Officials and Managers (EEO-1 Job Categories-United States of America)
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