Transfer Pricing Assistant Manager

Responsibilities

Purpose and aim of the role

The role requires an ambitious, confident individual, with a strong academic background to join the growing Corporate Tax Team as a Transfer Pricing Assistant Manager. The successful candidate will be a member of the Team, responsible for assisting the Transfer Pricing Director and Corporate Tax Partners in servicing clients, covering the complete cycle of Transfer Pricing advisory and compliance work.

The candidate will take ownership of the delivery of Transfer Pricing services and delegating work to the more junior people within the team. The role is in London (or potentially Manchester based with regular business travel required to London).

Transfer pricing projects can involve:

• Planning and design of Transfer Pricing policies for all transaction types (including tangible goods, services, intellectual property and financing) covering various business operating models
• Preparation and review of Transfer Pricing documentation including benchmarking studies e.g. Master Files, Local Files and Country-by-Country Reporting
• Review and guidance on implementation of Transfer Pricing policies e.g. financial and operational testing of policies, comment on agreements prepared by legal advisors
• Review of intercompany financing arrangements
• Thin capitalisation reviews
• Transfer pricing risk reviews of cross-border operations and remediation advice
• Advance Pricing Agreement and Mutual Agreement Procedure cases
• Dispute resolution with tax authorities
• Awareness of broader tax considerations of Transfer Pricing policies and cross-border operations e.g. withholding taxes, VAT/customs duties and permanent establishment risks

The team has an entrepreneurial culture and offers accelerated learning with high exposure to project management and client relationships. Training and coaching will be provided to support ongoing professional development.

The team is growing and promotion opportunities will be available in the future for a successful and ambitious candidate.

Client Responsibilities

The tax team deals with a broad range of Transfer Pricing advisory and compliance work, emanating from a wide variety of clients.

Key responsibilities to be carried out are:

• Liaison with the wider tax team, tax audit and accounting teams and other service lines in respect of upcoming work and delivery timetable
• Management of deadlines in a timely manner in respect of client work allocation
• Build and maintain relationships with clients and provide high levels of client service
• Manage WIP and billing for own clients, ensuring commercial recoveries
• Management of more junior members of the team to deliver work and provision of feedback
• Responsibility for adherence with the firm's risk management procedures and some administrative tasks

Special work/ad hoc assignments

Work may include the following:

• Tender proposals
• Tax audit support
• Due diligence support
• Opportunities to train staff on Transfer Pricing matters
• Defence and resolution of tax authority enquiries
• Liaison with international colleagues
• Assistance in team and firm marketing initiatives

* ACA/CA/CTA/ADIT or equivalent
* Proven skills and experience in Transfer Pricing gained in practice and/or industry
* A good understanding of the OECD Transfer Pricing Guidelines
* Able to explain complex issues in a way non-tax specialists can clearly understand
* Up-to-date technical skills and experience, across a broad range of businesses
* Ability to manage work within budgets and deadlines
* Good report writing skills (including Master Files, Local Files and specialist input into due diligence and tax audit reports)
* Ability to build relationships with clients, colleagues and across a global network of TP professionals.

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As an employer, we are committed to ensuring the representation of people from all backgrounds regardless of their gender identity or expression, sexual orientation, race, religion, ethnicity, age, neurodiversity, disability status, or any other aspect which makes them unique. We welcome applicants from all backgrounds to apply and would encourage you to let us know if there are steps, we can take to ensure that your recruitment process enables you to present yourself in a way that makes you comfortable.