Manager, Transfer Pricing & International Tax

Accountabilities:

• • Own and continuously enhance the group’s transfer pricing framework, policies, governance processes, and contemporaneous documentation, ensuring alignment with the organization’s actual functions, assets, and risks.
  • Lead the preparation and review of Canadian and international transfer pricing documentation, including local files, master files, supporting analyses, T106 and T1134 reporting, as applicable.
  • Develop scalable transfer pricing processes, controls, data requirements, and calculation methodologies suitable for a rapidly growing organization.
  • Identify opportunities to automate transfer pricing calculations, data collection, monitoring, and reporting to improve efficiency and accuracy.
  • Lead transfer pricing analyses covering intercompany services, technology and intellectual property arrangements, financing, guarantees, cost allocations, and other related-party transactions.
  • Assess appropriate transfer pricing methodologies and oversee economic benchmarking and related analyses.
  • Monitor intercompany transactions and identify discrepancies between transfer pricing policies, agreements, and actual business activities.
  • Review and help design intercompany agreements and supporting documentation, ensuring they are technically robust and commercially practical.
  • Monitor business developments and proactively identify transfer pricing implications arising from new products, entities, jurisdictions, and changes to operating models.
  • Manage external advisors on special projects, ensuring high-quality deliverables, sound technical conclusions, and practical recommendations.
  • Support transfer pricing audits, tax authority inquiries, and tax controversy matters.
  • Build strong relationships across the organization and identify tax considerations early in the business decision-making process.
  • Support broader international tax initiatives as the organization expands into additional markets.
  • Monitor developments in international tax legislation, bilateral tax treaties, and OECD initiatives, assessing their potential impact on the business.

  Requirements:

  • 5–8+ years of relevant professional experience in transfer pricing, international tax, tax advisory, or a closely related field.
  • Strong knowledge of Canadian transfer pricing legislation and OECD transfer pricing principles.
  • Hands-on experience with Canadian transfer pricing documentation, including T106 and T1134 reporting.
  • Demonstrated experience working with intercompany transactions and multinational or cross-border operating models.
  • Strong understanding of transfer pricing methodologies, economic benchmarking, and related-party transaction analysis.
  • Experience managing transfer pricing projects from analysis through implementation and documentation.
  • Strong analytical and problem-solving capabilities, with the ability to evaluate complex transactions and develop practical, commercially sound solutions.
  • Excellent written and verbal communication skills, including the ability to explain sophisticated tax concepts clearly to non-tax stakeholders.
  • Strong project management skills, with the ability to manage multiple priorities and deliver high-quality work in a fast-paced environment.
  • CPA, CA, LL.M., or another relevant professional designation is an asset.
  • Experience in fintech, financial services, technology, or another rapidly evolving industry is an advantage.
  • Additional experience with U.S. tax, international transfer pricing, intercompany financing, guarantees, technology, intellectual property, centralized services, tax audits, controversy, tax technology, automation, or data analytics is considered a plus.
  • A proactive, collaborative, and business-oriented mindset, with the ability to operate independently while building trusted relationships across functions.

  Benefits:

  • Competitive compensation package aligned with experience and role scope.
  • Top-tier health benefits and life insurance.
  • Long-term group savings plan with employer matching.
  • 20 vacation days annually, plus 4 wellness days.
  • Unlimited sick and mental health days.
  • Flexibility to work outside Canada for up to 90 days per year.
  • Hybrid work environment with collaboration across a large North American team.
  • Opportunities to work alongside talented, curious, and highly driven colleagues.
  • Employee resource groups supporting inclusion and community, including groups focused on 2SLGBTQ+ employees, women, and Black employees.
  • Opportunities for professional growth and expanded responsibilities as the organization develops its international footprint.
  • Exposure to innovative financial products, cross-border transactions, evolving business models, and strategic tax initiatives.
  • An environment that encourages the use of technology, AI, and new approaches to improve how teams work.
  • Commitment to an inclusive and accessible workplace, with accommodations available throughout the hiring process.