Manager, Transfer Pricing – International Tax

This is a fully remote position, open to applicants in Canada.

📋 Description

• Take ownership of, update, and manage the group’s transfer pricing framework, policies, governance processes, and contemporaneous documentation.

• Lead the creation of Canadian and international transfer pricing documentation, including local files, master files, and supporting analyses.

• Develop efficient and scalable transfer pricing processes, controls, and governance mechanisms.

• Identify opportunities to automate transfer pricing calculations, data collection, and reporting procedures.

• Conduct transfer pricing analyses for intercompany services, technology and intellectual property arrangements, financing, guarantees, cost allocations, and other related-party transactions.

• Evaluate transfer pricing methodologies and supervise benchmarking and economic analyses.

• Oversee transfer pricing calculations, data requirements, and related processes.

• Monitor intercompany transactions and pinpoint discrepancies between policies, agreements, and actual activities.

• Review and/or create intercompany agreements and supporting documentation.

• Determine the transfer pricing implications of new products, entities, jurisdictions, and changes in the operating model.

• Manage external advisors for special projects, ensuring the delivery of technically sound and commercially viable outcomes.

• Assist with transfer pricing audits, inquiries from tax authorities, and other controversy matters.

• Foster relationships throughout the organization and identify tax considerations prior to finalizing business decisions.

• Provide support for broader international tax issues as the company grows.

• Keep abreast of international tax regulations, bilateral tax treaties, and OECD initiatives, assessing their impacts on the business.

⛳️ Requirements

• 5–8+ years of relevant experience in transfer pricing, international tax, or tax advisory services.

• In-depth knowledge of Canadian transfer pricing regulations and OECD transfer pricing principles.

• Proficiency in Canadian transfer pricing documentation, including T106 and T1134 reporting.

• Familiarity with intercompany transactions and multinational or cross-border operating models.

• Strong grasp of transfer pricing methodologies and economic benchmarking.

• Experience in managing transfer pricing projects effectively.

• Excellent analytical and problem-solving abilities.

• Outstanding written and verbal communication skills, particularly in conveying technical tax concepts to non-tax stakeholders.

• Strong project management capabilities and the ability to juggle multiple priorities in a fast-paced environment.

• CPA, CA, LL.M., or another relevant professional designation is advantageous.

• Experience in fintech, financial services, technology, or a rapidly expanding industry is a plus.

• Knowledge of U.S. tax or other international transfer pricing practices is beneficial.

• Familiarity with intercompany financing and guarantee arrangements is a bonus.

• Experience with technology, intellectual property, or centralized service agreements is advantageous.

• Previous involvement with transfer pricing audits or tax controversy is desirable.

• Experience with tax technology, automation, or data analytics is a plus.

• Must be legally eligible to work in Canada.

🏝️ Benefits

• Comprehensive health benefits and life insurance coverage.

• Long-term group savings plan with employer matching through Wealthsimple for Business.

• Enjoy 20 vacation days per year.

• Receive 4 wellness days annually.

• Unlimited sick and mental health days each year.

• Opportunity to work outside Canada for up to 90 days each year.

• Access to employee resource groups, including Rainbow (2SLGBTQ), Women of WS, and Black at WS.

• Equity compensation available for permanent employees.