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Senior Manager, Transfer Pricing - 12 Month Contract (Closed)

This role is responsible for global transfer pricing strategic planning, communication, execution, analysis, documentation and audit defense in the following tax jurisdictions: Canada, United States, Mexico, Germany, Slovakia, Netherlands, Hong Kong, China, Japan, South Africa, and Brazil.

About the Opportunity

Transfer Pricing Strategic Planning & Communication

• Review and evaluate the company’s transfer pricing in line with current OECD and country-specific tax and transfer pricing rules and guidelines on an ongoing basis
• Work with the Tax group to assess impact of transfer pricing on other areas of tax, including the consolidated effective tax rate, U.S. base erosion and anti-avoidance taxes, foreign derived intangible income, withholding taxes, etc
• Communicate transfer pricing within the Tax group and to the relevant external parties in the organization

Transfer Pricing Execution & Analysis

• Perform regular updates to, analyses of, as well as prepare and communicate interim transfer pricing charges, accounting entries, and year-end adjustments for, the centrally managed intercompany transactions, including the global profit split model, corporate cost allocations models, and royalty model
• Communicate with the Finance group to ensure that other major intercompany transactions are being executed in accordance with the company’s transfer pricing policies and strategy
• Perform cost plus mark-up analyses to evaluate intercompany cost-based transactions
• Manage and review external benchmarking analyses, including comparable company, royalty rate, sales commission, interest rate, and other benchmarking, as may be required
• Periodically pull financial data from an SAP consolidated accounting system, review and sanity check legal entity financial results, and determine whether transfer pricing adjustments or other measures should be taken
• Understand, evaluate and respond to ad-hoc transfer pricing queries

Transfer Pricing Documentation Preparation & Management

• Gather the necessary information and financial data from various areas of the business, conduct fact-finding interviews with key personnel, work with relevant areas of the business for review, validation, and updates to the prior year documentation and analyses, manage and review external benchmarking or other consulting services, etc
• Prepare in-house transfer pricing documentation, including a global master file, country-by-country reporting, and legal entity local files that meet local transfer pricing requirements in Canada, United States, Mexico, Germany, Slovakia, Netherlands, Hong Kong, China, Japan, South Africa, and Brazil
• Work with internal legal counsel to prepare or update intercompany legal agreements, as needed

Audit Defense Support

• Ongoing transfer pricing audits are currently taking place in Germany, Mexico, and Canada
• Lead and manage audit defense, working with external transfer pricing consultants or tax legal counsel, as needed
• Obtain a strong understanding of historical transfer pricing policies and intercompany transactions
• Gather and analyze relevant information to build audit support, work with several areas of the business to gather facts, information and data, determine sound arguments, and prepare professional written audit responses

About You

• Bachelor’s university degree
• 6+ years of transfer pricing experience
• Accounting/Finance educational background
• 2+ years of in-house transfer pricing experience
• CPA or CFA designation
• Graduate or higher university degree
• Technical proficiency in Microsoft Office (particularly, Excel)
• Additional business management educational background or experience
• Effective communicator with a professional presence in order to facilitate the establishment of strong working relationships and ability to work closely with senior level business executives;
• Excellent organizational, time management, and multitasking skills to manage multiple tasks concurrently, meet deadlines, keep projects moving, and upward manage senior executives
• Strong technical aptitude with Microsoft Office, and in particular Microsoft Excel, to allow for efficiency of data gathering, analyses and ongoing tasks
• Keen attention to detail and sound financial understanding/reasoning to ensure accuracy and reasonability of work products
• Solid understanding of transfer pricing and ability to obtain all relevant facts and circumstances in order to evaluate transfer pricing policies and models, as well as respond to ad-hoc transfer pricing queries
• Strong professional writing skills in order to prepare in-house transfer pricing documentation, memorandums, corporate communications, review and assist with the preparation of intercompany legal agreements, and prepare professional written audit responses or other communications to tax authorities

Pay Rate

$125,000/year

How to Apply

Click the “Apply Now” button and follow the instructions to submit your resume. Please note that we only accept documents in MS Word or Rich Text formats. When referencing this job, quote #20880.

You must currently reside within the Greater Toronto Area and be permitted to work in Canada to be considered for this opportunity. A recruiter will be in touch with you if your profile meets our client’s requirements for this role.