PwC
Transfer Pricing - Senior Manager
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Transfer Pricing - Senior Manager
Senior Manager – Transfer Pricing Management
About the Role
We are seeking a Senior Manager to join our Transfer Pricing team, based in one of the following locations:
- London
- Birmingham
- East Midlands
- Bristol
- Cardiff
- Manchester
- Leeds
- Edinburgh
- Glasgow
- Belfast
- Aberdeen
This is an opportunity to be at the heart of a thriving business, working on complex and challenging projects, developing a client portfolio, and sharing in the success of the organisation. The role is project-based, primarily involving multinational companies across:
- Intercompany transactions (products, services, IP, debt)
- Transfer pricing risk management
- APA (Advanced Pricing Arrangement) negotiations and tax audits
Key Responsibilities
Daily Work Scope
- Manage transfer pricing risk, planning, and implementation for clients
- Coordinate European and global transfer pricing engagements with specialists
- Support business transformations (e.g., restructuring, value chain shifts)
- Guidance through audits, tax disputes, or regulatory reviews
- Oversee client portfolios and relationships, managing financial and risk aspects
- Delivery of high-quality, practical transfer pricing solutions
Candidate Profile
Qualifications & Experience
The role is ideal for candidates who have:
- Advised multinational clients on complex transfer pricing, including:
- Products, services, intellectual property (IP), and debt arrangements
- Strategic positioning for tax optimisation and compliance
- Developed innovative, commercially viable transfer pricing solutions
- Demonstrated early-stage business growth via networking, referrals, and cross-selling additional tax/business services
- Proven ability to manage multiple high-value projects
- Prior experience coaching, mentoring, or developing junior team members
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Preferred & Required Technical Skills
Degrees/Field of Study
- (Specified)
- Preferred:
- Taxation (Master’s degree or equivalent)
- Business or Economics (relevant research, exhibits, or specialisation would be an asset)
Certifications
- (Specified)
- Preferred:
- Chartered Tax Adviser (CTA) or Graduate Tax Technician (GTT)
- Advanced Transfer Pricing courses (e.g., CIOT/ICAEW)
Technical Skills
Core Skills
- Module Transfer Pricing (OECD Guidelines)
- Arms-Length Standard, BEPS Action Plan
- Intercompany agreement drafting and analysis
- APA negotiations (UN MODEL, EU Arbitration)
- RULAT, CFC rules, Hybrid instruments
- Global Tax Update & Compliance Regulations
- Indirect Tax considerations (e.g., VAT in cross-border transactions)
Optional Skills
- Accepting Feedback | Active Listening | Analytical Thinking
- Base Erosion and Profit Shifting (BEPS) | Business Taxation
- Coaching & Feedback Delivery | Consolidated Tax Returns
- Corporate Restructuring | Creativity (problem-solving)
- Financial Modelling | Financial Statement Analysis
- Legal Document Review (transfer pricing treaties, court proceedings)
- Macroeconomics | Economic Translation & Location Analysis
- يدهまる (frontline tax positions & drafting enforcement RMAs)
Soft Skills & Attributes
- Strong communication and negotiation skills (internal/external stakeholders)
- High integrity, independence, and strict confidentiality handling in a sensitive area
- Data-driven mindset, lifelong learning orientation
- Team leadership, collaboration, and role modelling
- Emotional regulation and resilience (balancing client delivery deadlines under uncertainty)
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Benefits & Flexibility
Work Arrangements
- Hybrid working model (blending office/remote/home based on client needs)
- Flexible week (supporting schedule adjustments while meeting deadlines)
Support & Wellbeing
- Private medical insurance + 24/7 virtual GP access
- Six volunteering days per year
- Health & wellbeing resources (lifestyle support, mental health initiatives)
- Unparalleled developmental opportunities through challenging work & mentorship
Professional Growth
- Mentorship and coaching for long-term career progression
- Exposure across PwC networks (tax & advisory firms globally)
- Elevated visibility to senior colleagues ('You’ll call on a network of peers’)
Financial & Tax Audits Assistance
(Where applicable, alignment with firm-wide tax services)
Desired Languages
- Basic reading ability in at least one of:
- Chinese
- Russian
- German
- Spanish (Plus English (Fluency required))
Travel
- Up to 60% of workweek away from office (client sites/ hesab tarafı)
Position Requirements
- Government Clearance: Not required
- Visa Sponsorship: Yes
Fresh roles available until: 31 January 2026
Why Join Us?
“At PwC, you’ll unlock your potential by applying your unique perspective. We combine innovation (turning challenges into growth) with a culture of trust and empathy, helping you navigate industry shifts and push forward.”
Your Journey Here:
- Discover hidden talents (skills you may not have realised you possessed)
- Build lifelong relationships within a collaborative global network
- Transform audits and regulatory hurdles into opportunity-driven solutions
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