Tax - Transfer Pricing Manager

Overview

We are seeking an experienced and proactive Transfer Pricing Manager to join the Group Finance function as the Group's dedicated in-house Transfer Pricing specialist, based in Kuala Lumpur, Malaysia.

This role is responsible for managing the Group's global transfer pricing framework, policies, compliance, documentation, intercompany transactions, and transfer pricing risk management across multiple jurisdictions. The position also oversees Country-by-Country Reporting (CbCR) and Pillar Two / Global Minimum Tax (GMT) compliance and reporting.

Working closely with Group Tax, Finance, Legal, Treasury, Operations, Business Development, and local teams worldwide, the successful candidate will play a key role in supporting the Group's international operations and ensuring compliance with OECD and local transfer pricing requirements.

Key Responsibilities

Transfer Pricing Strategy & Advisory

1. Develop, implement, and maintain the Group's global transfer pricing framework and policies.
2. Ensure consistent application of transfer pricing policies across all entities and jurisdictions.
3. Advise on intercompany transactions, business structures, financing arrangements, intellectual property, service arrangements, cost allocations, vessel charters, and other related-party transactions.
4. Conduct functional, economic, industry, and value chain analyses to support arm's length pricing.
5. Review and develop transfer pricing methodologies, benchmarking studies, and economic analyses.
6. Support business projects, restructurings, tenders, market entries, and operating model changes from a transfer pricing perspective.
7. Provide practical guidance to Finance, Legal, Operations, Treasury, and commercial stakeholders.

Transfer Pricing Compliance & Documentation

1. Manage global transfer pricing compliance requirements across relevant jurisdictions.
2. Prepare, review, and maintain Master Files, Local Files, transfer pricing reports, disclosures, and statutory filings.
3. Coordinate transfer pricing documentation and filing requirements within statutory deadlines.
4. Ensure documentation is accurate, consistent, and aligned with Group policies.
5. Monitor developments in OECD guidance, transfer pricing regulations, and international tax legislation.
6. Maintain transfer pricing records, supporting analyses, and intercompany agreements.

Operational Transfer Pricing

1. Monitor intercompany transactions and pricing outcomes to ensure policy compliance.
2. Support implementation of operational transfer pricing processes and controls.
3. Review intercompany agreements and pricing mechanisms.
4. Analyse transaction flows, balances, and financial data to identify transfer pricing risks and inconsistencies.
5. Coordinate year-end adjustments, true-ups, and corrective actions where required.
6. Work closely with Finance and Accounting teams to ensure alignment between transfer pricing policies and accounting treatment.

CbCR & Pillar Two/Global Minimum Tax

1. Lead the Group's Country-by-Country Reporting (CbCR) process.
2. Coordinate data collection, validation, review, filing, and compliance activities across jurisdictions.
3. Maintain supporting documentation and controls for CbCR reporting.
4. Manage Pillar Two / Global Minimum Tax compliance, reporting, calculations, disclosures, and filings.
5. Monitor OECD Pillar Two developments and local implementation requirements.
6. Partner with Finance, Tax, Accounting, and external advisors to address data and reporting requirements.
7. Identify and communicate risks, data gaps, and compliance implications to management.

Tax Risk Management & Audit Support

1. Identify, assess, and monitor transfer pricing risks across the Group.
2. Manage transfer pricing audits, tax authority enquiries, information requests, and controversy matters.
3. Prepare supporting analyses, defence files, and responses to tax authorities.
4. Coordinate with external advisors and local teams during audits and disputes.
5. Recommend risk mitigation strategies and support transfer pricing governance initiatives.

Stakeholder & Advisor Management

1. Act as the Group's primary transfer pricing contact for internal stakeholders.
2. Coordinate transfer pricing activities across multiple countries, entities, and functions.
3. Build strong relationships with Finance, Tax, Legal, Operations, and commercial teams globally.
4. Translate complex transfer pricing concepts into practical business advice.
5. Manage and review work performed by external transfer pricing advisors.

Process Improvement & Transformation

1. Drive continuous improvement in transfer pricing governance, compliance, and operational processes.
2. Develop standardised procedures, controls, templates, and reporting frameworks.
3. Improve data collection, validation, and reporting for transfer pricing, CbCR, and Pillar Two.
4. Leverage ERP systems, databases, and technology solutions to enhance efficiency and data quality.
5. Support tax transformation initiatives and scalable processes to support business growth.

Additional Responsibilities

1. Monitor developments in OECD Transfer Pricing Guidelines, BEPS initiatives, CbCR, Pillar Two, and international tax regulations.
2. Assess the impact of legislative changes on Group operations and transfer pricing policies.
3. Promote best practices in transfer pricing compliance, governance, and risk management.
4. Support broader Group Tax initiatives and special projects as assigned.

Essential Requirements

1. Bachelor's degree in Accounting, Finance, Taxation, Economics, Law, Business Administration, or a related discipline.
2. Minimum 5 years of transfer pricing experience gained within a Big 4 firm, tax advisory practice, law firm, or multinational organisation.
3. Strong technical knowledge of OECD Transfer Pricing Guidelines and transfer pricing principles.
4. Proven experience in transfer pricing documentation, benchmarking, economic analysis, and intercompany transaction reviews.
5. Experience managing transfer pricing matters across multiple countries and legal entities.
6. Knowledge of transfer pricing compliance requirements, including Master Files, Local Files, disclosures, and statutory filings.
7. Working knowledge of CbCR requirements.
8. Familiarity with Pillar Two / Global Minimum Tax frameworks.
9. Experience supporting transfer pricing audits and tax authority enquiries.
10. Strong analytical, financial modelling, Excel, and data management skills.
11. Ability to work independently and manage multiple priorities with minimal supervision.
12. Excellent stakeholder management, communication, and business partnering skills.
13. Strong written and verbal English communication skills.

Preferred Qualifications

1. Professional qualification such as ACCA, CPA, CIMA, CTA, ADIT, or equivalent.
2. Postgraduate or specialist qualification in Transfer Pricing, International Tax, Economics, Finance, or related fields.
3. Experience within the in-house tax function of a multinational group.
4. Hands-on experience with CbCR and Pillar Two compliance and reporting.
5. Experience managing global transfer pricing policies across multiple jurisdictions.
6. Familiarity with transfer pricing databases and benchmarking tools such as Orbis, RoyaltyStat, TP Catalyst, or similar.
7. Experience with NetSuite or other major ERP systems.
8. Exposure to multinational businesses in infrastructure, maritime, shipping, engineering, construction, energy, or asset-intensive sectors.
9. Experience supporting APAs, MAPs, tax audits, or transfer pricing disputes.
10. Understanding of OECD BEPS initiatives and international tax developments.
11. Experience leading process improvement, automation, standardisation, or tax transformation projects.