International Tax - Transfer Pricing Manager

We are seeking a Transfer Pricing manager to oversee the execution of our global intercompany pricing strategies. You will ensure that our cross-border transactions are compliant with OECD guidelines and local regulations, while working closely with the Finance and other functions to monitor profitability.

【Must】

Responsibilities

Documentation Management: Lead the preparation of the Global Master File, CbCR and Local Files for multiple jurisdictions with support from tax advisors.; Operational TP: Perform monthly/quarterly review to ensure legal entity margins remain within the target arm’s length range.; Audit Defense: Act as the primary point of contact for gathering data and drafting responses to Information Document Requests (IDRs) from tax authorities.; Intercompany Agreements: Partner with Legal to ensure intercompany contracts are up-to-date and reflect the economic substance of the business.; Tech Integration: Assist in the implementation of TP automation software to streamline data collection from ERP systems.

Requirements

5 or more years of experience in transfer pricing (Big 4 experience preferred).; Strong English communication skills and conversational Japanese level is preferred; Proficiency in Excel and financial modeling; Team work with multiple functions

Nice to have

APA experience; Semiconductor and/or manufacturing industry; Group restructuring; Cross boarder transactions and international tax; Corporate tax return preparation and tax audits correspondences; General accounting skills