Manager/ Senior Manager (Transfer Pricing)

About the Role

We are looking for a Transfer Pricing professional to own the Group's transfer pricing framework end-to-end - from policy design and economic analysis to documentation and controversy management - partnering closely with Finance, Legal, and other stakeholders across the different regions. Operating across multiple jurisdictions globally, this role will ensure the Group's TP position is commercially sound, well-documented, and aligned with OECD guidelines as the business continues to scale.

Key Responsibilities

Transfer Pricing Strategy & Policy

. Develop and maintain the Group's transfer pricing policies for intercompany flows, including performing Key Entrepreneurial Risk-Taking (KERT) functions analysis to support risk and profit allocation

. Design a sound, defensible transfer pricing cost allocation methodology for the Group and lead its rollout across all jurisdictions, ensuring consistent application and documentation

. Periodically review and refresh transfer pricing models to reflect evolving business operations and intercompany flows

Benchmarking & Economic Analysis

. Conduct functional and economic analyses of intercompany transactions, including benchmarking studies to support arm's-length pricing across the Group

. Build and maintain financial models to evaluate the pricing and tax impact of alternative transfer pricing structures

Documentation & Compliance

. Manage the Group's transfer pricing documentation (master file, local files) across all jurisdictions, partnering with the broader finance team and external advisors to ensure timely and accurate submissions

. Oversee intercompany agreements, ensuring they are properly documented, kept up to date, and aligned with actual business operations

. Coordinate transfer pricing aspects of statutory and tax filings, including liaison with external advisors on local TP filing requirements

Risk Management & Controversy

. Monitor intercompany transactions across the Group, identifying gaps between transfer pricing policies, agreements, and actual activity

. Maintain documentation of key transfer pricing positions and support the assessment of uncertain TP positions

. Monitor changes in transfer pricing legislation and OECD guidance relevant to the Group's jurisdictions, assessing impact and proactively advising the business

. Support transfer pricing audits, tax authority inquiries, and controversy matters, working with external advisors as needed

Business Partnering & Technology

. Assess the transfer pricing implications of new products, business lines, or market entries, providing practical, commercially minded guidance that supports business growth

. Advise on transfer pricing aspects of Group projects, including business restructurings, legal entity structuring, and cross-border intercompany financing arrangements

. Identify opportunities to automate transfer pricing calculations, data collection, and reporting partner with Finance and IT to implement or enhance supporting tools

What We're Looking For

. Minimum 10+ years of transfer pricing experience, ideally with a mix of Big 4 / advisory firm experience and in-house roles exposure to financial services, fintech, brokerage, capital markets, or related regulated industries is highly preferred

. Strong knowledge of OECD Transfer Pricing Guidelines and BEPS principles, with solid understanding of local TP rules across the Group's operating jurisdictions

. Strong technical skills in transfer pricing analysis, benchmarking, and documentation, with an analytical mindset and strong attention to detail

. A hands-on self-starter who is comfortable operating with ambiguity in a fast-paced, start-up-like environment, and is equally willing to execute detailed work as to advise at a strategic level resourceful and adaptable

. Excellent written and verbal communication skills, including the ability to translate complex transfer pricing concepts into clear, practical recommendations for non-tax stakeholders

. Familiarity with AI and its applications in tax processes (e.g., compliance automation, data analysis, process improvement) is a plus

. Bachelor's degree in Accounting, Finance, Economics, or a related discipline

. Professional accounting qualification (CPA, ACCA, CA, or equivalent) required

. Strong English proficiency required spoken Chinese proficiency advantageous to support collaboration with regional colleagues and external stakeholders