Gunvor Group
Transfer Pricing Senior Manager
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Transfer Pricing Senior Manager
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Job Description:
The Transfer Pricing Senior Manager is responsible for overseeing and managing the company's transfer pricing policies, documentation, and compliance across all jurisdictions. This role involves developing and implementing transfer pricing strategies, ensuring adherence to international regulations, and supporting audits and disputes related to transfer pricing matters.
Role Summary:
Based in our offices in Madrid (alternatively Amsterdam) and reporting directly to our Global Head of Taxes, the Transfer Pricing Senior Manager is responsible for overseeing and managing the company's transfer pricing policies, documentation, and compliance across all jurisdictions. This role involves developing and implementing transfer pricing strategies, ensuring adherence to international regulations, and supporting audits and disputes related to transfer pricing matters.
Main Responsibilities
Strategic & Advisory Responsibilities
- Develop and continuously refine the Group’s transfer pricing strategy in alignment with evolving business models (trading, assets, shipping, GBS, new geographies).
- Provide expert advice to the Global Head of Taxes and senior business stakeholders on TP implications of new ventures, restructurings, M&A, and intra‑group financing.
- Lead the annual global TP planning cycle, including profit allocation models, pricing policy refreshes, and adjustments to intercompany flows.
Operational & Compliance Responsibilities
- Oversee end‑to‑end preparation of Master File, Local Files, CBCR, transactional reports, and benchmarking studies across all jurisdictions.
- Ensure timely and accurate implementation of intercompany agreements (ICAs), including monitoring consistency between legal terms and actual conduct.
- Review and validate monthly and quarterly transfer pricing calculations (profit splits, margin testing, CUP analyses, trader remuneration mechanisms, etc.).
- Maintain and update the TP control framework integrated within the Group’s Internal Control over Financial Reporting (ICFR).
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Audit, Risk Management & Disputes
- Serve as the primary contact for TP audits globally; prepare defense files, respond to tax authority inquiries, and manage dispute resolution strategies.
- Coordinate with external advisors and internal teams to minimize tax controversy risk through proactive documentation and robust modelling.
- Monitor global TP regulatory changes (OECD, EU, UN, local tax authorities) and assess their impact on Group’s model.
Cross-Functional Collaboration
- Work closely with Trading, Legal, Controlling, Accounting, and Finance to embed transfer pricing requirements into processes and decisions.
- Support the integration of new markets and entities into Group’s TP model (e.g., expansion into Africa, Eastern Europe, assets strategy).
Data, Analytics & Process Improvement
- Enhance the use of data analytics and Power BI dashboards for monitoring margins, intercompany flows, and TP KPIs.
- Lead continuous improvement initiatives to streamline and automate TP calculations, documentation workflows, and risk monitoring.
People Development & Knowledge Building
- Train finance and accounting teams globally on TP concepts, implementation practices, and compliance expectations.
- Mentor junior tax and controlling staff (even without formal managerial responsibility).
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Profile
- CPA, ACCA, CA, or equivalent accounti/taxing certification.
- Preferred: Master’s degree in Taxation, Finance, Economics, or related field.
- 5-7 years of transfer pricing experience (Big 4, multinational trading/energy company, or complex global MNE).
- Strong exposure to trading environments, commodities, or supply‑chain‑heavy businesses is a significant advantage.
- Experience managing or coordinating TP audits and dispute resolution in multiple jurisdictions.
- Deep understanding of OECD TP Guidelines, BEPS, EU/J5 initiatives, and local statutory requirements.
- Advanced financial modelling skills; ability to interpret complex business flows and translate them into TP models.
- Strong command of IFRS and local GAAP interactions with transfer pricing.
- Experience designing and maintaining profit split methodologies, TNMM benchmarking, and economic analyses.
- High proficiency in MS Excel, Power BI, and data tools used for transactional analysis.
- Strategic, analytical, and structured thinker with an ability to simplify complexity.
- High degree of autonomy, judgment, and accountability in a fast‑paced, high‑stakes environment.
- Strong influencing skills; able to communicate effectively with traders, senior finance leaders, auditors, and authorities.
- Project leadership abilities, including managing multiple jurisdictions and external advisors.
- Excellent oral and written skills in English.
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