国際税務 - 移転価格マネージャー
Core
Lead global intercompany pricing strategy to ensure cross-border transactions comply with OECD guidelines and local regulations while monitoring profitability with finance and other departments.
Role type
Senior intercompany pricing manager (transfer pricing)
Builds
Transfer pricing documentation (Master File, CbCR, Local Files), pricing compliance monitoring, and intercompany contract alignment.
Domain
Semiconductor manufacturing / Embedded systems / Automotive / Industrial / IoT
Deliverable
production ML models | product features | dashboards & analysis | research | client delivery | infrastructure | physical/clinical work
Required skills
Transfer pricing expertise, English communication, Excel, financial modeling, cross-functional collaboration
Preferred skills
Advance Pricing Agreement (APA) experience, semiconductor/manufacturing industry experience, group restructuring experience, international tax knowledge, corporate tax filing experience, general accounting skills
Technologies
ERP systems, transfer pricing automation software
Responsibilities
Lead creation of Master File, Country-by-Country Report (CbCR), and Local Files with external tax advisor support; Review monthly/quarterly margins to ensure compliance with arm's length principles; Act as primary contact for tax authority information requests (IDR); Ensure intercompany contracts reflect economic substance; Support implementation of transfer pricing automation software.
Seniority
Senior, hands-on IC
