Head of Transfer Pricing
Core
Lead the global transfer pricing strategy, policies, and operating model for a trading group's logistics, financing, and asset-holding activities.
Role type
Senior Head of Transfer Pricing
Builds
Global transfer pricing frameworks and documentation for trading, shipping/logistics, and asset-holding activities
Domain
International Tax / Transfer Pricing
Required skills
Transfer pricing strategy, OECD guidelines, international tax principles, tax audit management, dispute resolution, APA negotiations, cross-border structuring, supply chain pricing analysis
Preferred skills
Professional qualifications (CA, CPA, ATP), commodities/trading/shipping/logistics industry experience, building internal TP capabilities
Technologies
Master file, local files, country-by-country reporting, AI-assisted recruitment tools
Responsibilities
Own and lead the group's global transfer pricing strategy, policies and operating model; Design and implement TP frameworks for trading, shipping/logistics, financing and asset-holding activities; Oversee TP documentation, including master file, local files and country-by-country reporting; Lead tax authority audits, disputes and advance pricing agreement (APA) negotiations where relevant; Advise the business on the TP implications of new structures, acquisitions, investments and supply chain changes; Monitor and assess the impact of global developments, including OECD BEPS and Pillar Two; Partner with finance and operations teams to ensure intercompany pricing is applied correctly and consistently; Manage external advisors and, over time, build out a transfer pricing capability within the team
