Manager/ Senior Manager (Transfer Pricing)

About Hytech

Hytech is a leading management consulting firm headquartered in Australia and Singapore, specialising in digital transformation for fintech and financial services organisations. We deliver end-to-end consulting services and provide robust middle- and back-office solutions that enable our clients to optimise operations, enhance efficiency, and stay ahead in a fast-evolving digital landscape.

With more than 2,000 professionals worldwide, Hytech has a strong and growing international presence, with offices across Australia, Singapore, Malaysia, Taiwan, the Philippines, Thailand, Morocco, Cyprus, Dubai, and beyond.

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 (including fintech, brokerage, and crypto-adjacent offerings), 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