Overview
Transfer Pricing Manager (Hybrid – 2‑3 days per week on site, occasional international travel) within the Group Tax team. The role reports to the Head of Transfer Pricing and focuses on driving value and minimizing tax risk across the Group’s 40+ territories.
Responsibilities
* Support the Head of Transfer Pricing on delivery of the Group’s transfer pricing strategy, policies and compliance obligations in all relevant jurisdictions (Master File, Local File, CBCR, pCBCR).
* Collaborate with business units, Corporate & Compliance teams, international tax teams, finance teams and the external advisory network on transfer‑pricing matters.
* Assist with transfer‑pricing tax disputes, MAP and APA processes, audits and engagement with regional tax teams and external advisers.
* Advise businesses on transfer‑pricing implications and risks associated with cross‑border transactions in existing, evolving or new business and operating models.
* Source relevant tax advice through the global advisor network when required.
* Stay up‑to‑date with international transfer‑pricing legislation, BEPS developments and tax‑authority guidance, and communicate implications to the Group.
* Help resolve transfer‑pricing issues for the Head of Transfer Pricing and tax teams worldwide.
* Manage transfer‑pricing elements of group reporting, forecasting and the Group tax disclosure policy.
* Lead continuous‑improvement initiatives to improve processes, standardise, simplify and automate transfer‑pricing work.
* Provide training to businesses and functions on transfer‑pricing risks and their management.
* Manage ad‑hoc projects and advice supporting the Head of Transfer Pricing.
Qualifications
* Degree‑level qualification or equivalent.
* Professional tax qualification or equivalent.
* Substantial post‑qualified experience.
* Relevant experience at manager level in transfer pricing (practice or industry) including tax‑efficient supply‑chain planning.
* Experience with cost‑sharing agreements.
* Detailed understanding of BEPS requirements, OECD TP guidelines, OECD Report on Business Restructurings and HMRC’s compliance guidelines.
* Experience managing dispute resolutions with tax authorities in APA and MAP situations.
* Strong business acumen and curiosity to understand complex business models.
Benefits
* Generous annual leave.
* Retirement savings through the Rolls‑Royce Retirement Savings Trust.
* Group life assurance (lump‑sum benefit if deceased whilst employed).
* Income protection providing income in the event of illness or injury.
* Shares scheme – matched shares, buy one share, get one free.
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