The Transfer Pricing Manager ("TPM") reports to the International Tax Director and is responsible for global transfer pricing planning, execution, reporting, and audits. The TPM partners with business units within the organization to develop and promote the implementation of cross-functional transfer pricing models that reflect business operations, optimize tax efficiency, and adequately mitigate risks. Accordingly, the TPM will work directly with regional and business unit professionals to provide transfer pricing guidance on intercompany transactions and collaborate effectively with applicable key stakeholders within Global Tax, Corporate Finance, and Import/Export to facilitate the accurate and timely implementation of the transfer pricing policy. The degree of these interactions will make this a very important role within the Global Tax department and provide significant opportunity for professional growth and development. The role will also include managing the preparation of various types of documentation, including BEPS-compliant Country by Country reports, local, and master files, to support controlled transactions undertaken by the Company.
Manage, implement, and support global transfer pricing strategic projects such as business supply chain planning, business restructurings, acquisition integration, etc.
Conduct detailed economic and financial analyses to determine optimal solutions to intercompany transaction flows (tangible assets, intangible assets, services, etc.)
Proactively identify and manage transfer pricing risks by ensuring consistent application of transfer pricing practices and documentation for global intercompany transactions, including new acquisitions.
Identify transfer pricing issues and propose strategies to mitigate risks.
Prepare and/or review contemporaneous, audit-ready benchmarks, transfer pricing reports, such that they comply with relevant transfer pricing requirements (US and BEPS) and support positions reliable enough to withstand questioning under audit by taxing authorities. Ensure country-by-country reporting is compliant.
Collaborate with the corporate import/export customs groups when setting transfer prices.
Independently review and perform testing on the intercompany transactions to determine whether adjustments should be made to the transfer prices and ensure such changes are executed accurately.
Proactively identify, track and determine the transfer pricing impact of organizational and/or business changes and assess any related party transactions to identify opportunities to develop appropriate tax strategies.
Assist in tax audit defense for both U.S. and foreign entities and provide management with strategic defense options and develop strategic responses to IDRs.
Evaluate the advantages of obtaining APAs and coordinate the process of obtaining and/or renewing APAs.
Review, draft, implement and maintain intercompany agreements to properly document and support transfer prices.
Partner with Finance and IT to establish and consistently improve the data management process in order to identify, analyze, determine and test transfer prices for inter-company transactions.
Acquire and be able to utilize systems skills that will allow work to be done within SAP, utilizing custom queries and reports.
Monitor legislative and statutory tax changes and assess potential impact to the Company and effectively and efficiently respond to evolving tax rules.
Build and maintain close working relationships across various corporate and business functions throughout the organization to help facilitate timely and accurate transfer pricing positions and reporting.
Supervise professional staff and support automation of processes and data collection.
EOE, M/F/Disabled, Vet #LI-MM1
Internal Number: 2556448
About Rockwell Automation
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