Transfer Pricing Senior Manager

Transfer Pricing Manager or Senior Manager

Overview

A rapidly scaling, international technology‑enabled business is strengthening its Tax function and is hiring a Transfer Pricing Manager to take ownership of its global transfer pricing framework. Operating across multiple geographies and launching new products and operating structures, the business views transfer pricing as a strategic enabler of growth, not a compliance afterthought.

This is a newly created role offering the opportunity to shape how transfer pricing supports the company’s expansion from the ground up.

The Role

As Transfer Pricing Manager, you will own the tax architecture underpinning the global operating model, ensuring intercompany structures are commercially aligned, defensible, and compliant as the business evolves.

You will play a core role in new product and country launches, partnering closely with senior tax leadership and cross‑functional stakeholders across Finance, Legal, Product, and Operations.

Key Responsibilities

Own the Global Transfer Pricing Framework

• Own and evolve the global transfer pricing policy to align with the business’s operating strategy and growth plans
• Maintain and develop intercompany agreements and documentation, including master file and local file frameworks, in coordination with external advisors
• Monitor global transfer pricing developments, including OECD guidelines and BEPS‑related changes, and assess their impact on the business
• Proactively identify transfer pricing risks and opportunities, ensuring positions are robust and defensible across jurisdictions
• Optimise tax effectiveness across intercompany flows while balancing commercial and operational realities

Support New Products and Market Expansion

• Act as a core member of launch teams for new products and geographies
• Provide early‑stage transfer pricing input to ensure structural decisions are addressed prior to go‑live
• Design and support implementation of transfer pricing models that enable confident market entry
• Partner with local advisors to ensure intercompany arrangements are appropriately documented and executed from inception

Be a Strategic Tax Partner

• Serve as a trusted advisor to senior stakeholders, making complex transfer pricing issues clear and actionable for non‑tax audiences
• Translate technical analysis into concise decision frameworks: key considerations, options, and trade‑offs
• Partner closely with senior tax leadership to identify risks and opportunities, shape tax priorities, and influence the long‑term direction of the Tax function
• Identify opportunities to strengthen transfer pricing processes, systems, and resourcing as the organisation scales

About You

Experience

• Proven transfer pricing specialist with strong technical expertise and hands‑on in‑house ownership of TP models
• Experience in technology‑driven, fintech, or globally distributed businesses with complex intercompany arrangements
• Track record supporting new country launches, new products, or evolving operating models
• Comfortable making sound transfer pricing decisions in high‑growth, ambiguous environments
• Strong practical knowledge of OECD Transfer Pricing Guidelines and BEPS principles

Skills & Approach

• Commercially minded, with an emphasis on enabling growth rather than creating friction
• Collaborative and solution‑oriented — a partner to the business, not a gatekeeper
• Clear, confident communicator able to simplify technical concepts for varied audiences
• Strong project management and prioritisation skills
• Ownership mindset, with experience designing, implementing, and defending TP structures
• Curious, adaptable, and energized by evolving business complexity

Qualifications

• Qualified accountant or tax professional (e.g., ACA, ACCA, CTA, or equivalent)
• Operating at Manager or Senior Manager level

Growth & Development

The organisation places significant emphasis on development and long‑term career progression. While this role is initially focused on transfer pricing, there is scope to expand into broader tax leadership responsibilities over time, depending on performance and interest.

The business prioritises building around strong individuals, offering flexibility for the role to evolve beyond its initial remit.