Transfer Pricing Manager job
To work on all matters relating to the transfer pricing affairs of the Banking Group, taking responsibility for transfer pricing methodologies, documentation, agreements, calculations and process, invoicing, document retention, etc.  Essentially this is a wide ranging transfer pricing role, and the candidate will be proactively driving the transfer pricing agenda across all legal entities and business lines in the Group.

• Undertaking detailed and comprehensive functional, organisational and economic analyses on business lines and legal entities
• With the support of the International Head of Tax, developing appropriate transfer pricing methodologies in relation to both revenues and costs, taking into account OECD thinking and local rules and practice
• Undertaking, where necessary and with the support of external advisors, benchmarking studies
• Developing sustainable tax return filing positions in relation to transfer pricing and permanent establishment issues

Documentation:

• Preparing comprehensive transfer pricing documentation for all transfer pricing arrangements within the Group
• Maintaining and updating documentation in line with local requirements for the purposes of tax audit
• Preparing documentation in relation to all aspect of the Finance process impacting on any of the transfer pricing arrangements in place (i.e. assumptions, criticalities, cost / revenue allocation models, etc) 

Agreements:

• Working with Legal and local management, implementing transfer pricing agreements for all transfer pricing arrangements within the Group

Calculations and process:

• Working with Finance to ensure the correct implementation and calculation of transfer pricing based on the transfer pricing methodologies adopted
• Back testing and analysis of transfer pricing for control and management reporting purposes
• Development of systems (working with Finance, business areas, etc) to produce numbers (e.g. for sales credits) compatible with the transfer pricing methodologies adopted

Invoicing

• Working with Finance to ensure appropriate invoicing arrangements
• Ensuring the correct application of indirect taxes to transfer pricing payments

Other

• Assisting locations with transfer pricing audits
• Ensuring that systems and processes are in place to maintain all documentation and numerical audit trail for audit purposes
• Working with the International Head of Tax to analyse tax risk in relation to transfer pricing and, where necessary, to provision and report to management on such risk
• Ensuring full communication with all stakeholders on transfer pricing matters
• Working on new product proposals and business initiatives to develop appropriate transfer pricing arrangements

About you
Given the nature and scope of the role, the candidate should have a strong background in financial services transfer pricing and ideally be working (or have worked) in the in-house tax department of a bank or similar institution. The candidate should be appropriately qualified (ATII / CTA / HMRC trained).  Strong numeracy, accountancy and computer skills will be required.

In view of the likely need to interact daily with different areas of the bank, the candidate should possess excellent interpersonal skills and an ability to develop good working relationships.  The candidate should be a strong self-starter and must be capable of functioning both autonomously – working largely under their own supervision – and within a team.  Good organisational skills are therefore also essential.

This role is very hands-on and will require a significant amount of analytical work and interaction with Finance in relation to process and the detailed implementation of transfer pricing arrangements.  Candidates who have worked in transfer pricing roles in a more advisory / managerial capacity may not have the practical experience required, and this will be tested in the interview process.

This is a stand-alone role, although the candidate will have the support of members of the tax department as well as staff in other areas impacted by transfer pricing (e.g Finance).  Without the direct support of a transfer pricing team, the successful candidate will find the workload challenging, but the role will be varied and highly rewarding.

The role may involve some travel (potentially to South Africa, Africa, Asia and South America).

Next step
Please contact our financial services expert, Catherine Nash.