Transfer Pricing Manager - US
Core
Senior US transfer pricing expert responsible for managing US operations, Cymer business, APA/BAPA, controversy, and compliance for a global semiconductor company.
Role type
Senior IC tax manager (transfer pricing)
Builds
US transfer pricing policies, APA/BAPA agreements, operational pricing models, and compliance deliverables
Domain
Semiconductor industry + International Tax / Transfer Pricing
Required skills
US transfer pricing principles, functional analysis, APA/BAPA management, tax controversy resolution, intercompany transaction modeling, tax provisioning, stakeholder management, policy development, data analysis, ERP familiarity
Preferred skills
Advanced tax degree (MAcc, MSc), CPA, recurring APA reporting experience, experience with Cymer or similar operating models
Technologies
ERP systems, consolidation tools, planning tools
Responsibilities
Lead US APA/BAPA and controversy work including fact pattern coverage and audit readiness; oversee operational transfer pricing calculations and reconciliations; develop and implement global TP policies; coordinate with US business, Finance, Legal, and Tax stakeholders; manage TP compliance calendar and local file delivery; assess changes in operating models and intercompany flows.
Seniority
Senior, hands-on IC
