Transfer Pricing Senior Manager (EPC Environment)
Job
Overview
- IT and Telecoms
- Finance, HR and Administration
- Permanent
- Texas
Transfer Pricing Senior Manager (EPC Environment)
A global EPC firm is seeking a hands-on Transfer Pricing Senior Manager to lead and support transfer pricing planning, execution, and documentation across multiple jurisdictions. This role requires a seasoned professional with strong OECD and U.S. transfer pricing knowledge, proven experience partnering with Big 4 firms, and a practical, roll-up-your-sleeves mindset—someone who is detail-driven, execution-focused, and comfortable owning deliverables end-to-end.
This position supports transfer pricing policy, documentation, and operational alignment for large-scale global EPC operating entities, partnering closely with Finance, Legal, and business leadership.
Key Responsibilities
• Lead and maintain the company’s global transfer pricing policy (intercompany services, IP/royalties, cost allocations), ensuring alignment with business operations
• Oversee annual transfer pricing documentation (Master File/Local File where applicable), benchmarking support, and intercompany agreements in coordination with local legal team and external advisors
• Oversee implementation and monitoring of intercompany pricing and true-ups, including calculations, and coordination with both project and corporate accounting for timely bookings
• Serve as primary liaison with external firms on transfer pricing planning, documentation, audits, and controversy support
• Advise on transfer pricing implications for global EPC projects, joint ventures, and cross-border project structures (including permanent establishment considerations where relevant)
• Partner with Tax Accounting on ASC 740 transfer pricing-related reserves, uncertain tax positions, and effective tax rate impacts
• Provide operational guidance to Finance and business teams on intercompany billing, cost allocations, and data requirements to support documentation and audit readiness
• Support transfer pricing audits and inquiries (IRS, foreign tax authorities), including responses to information requests, position papers, and coordination with counsel/advisors
• Maintain transfer pricing controls, calendars, and documentation standards, drive process improvements and consistency across jurisdictions
Qualifications - Required
• 7+ years of progressive transfer pricing experience (in-house and/or public accounting)
• Proven experience partnering with Big 4 firms or outside legal counsel on transfer pricing documentation, planning, and/or controversy matters
• Experience in engineering, construction, EPC, or project-based global organizations, with an understanding of cost structures and project execution models a strong plus
• Experience in pulling and analyzing detailed information from financial accounting systems
• Strong project management skills, attention to detail, and ability to lead complex workstreams with minimal oversight
Preferred Skills
• Experience supporting global operations across multiple jurisdictions, including OECD-aligned documentation requirements
• Knowledge of cross-border EPC project structures, intercompany service models, and cost allocation methodologies
• Ability to thrive in a fast-paced, deadline-driven environment while balancing strategic advisory and hands-on execution
• Bachelor’s degree in tax or accounting and/or CPA preferred
• Experience in US International taxation a plus.
Key Skills & Attributes
• Global Transfer Pricing Policy, Planning & Governance
• Transfer Pricing Documentation (Master File/Local File) & Audit Defense Support
• EPC / Project-Based Business Understanding & Cost Allocation Methods
• Strong Excel & financial systems skills; ability to translate data into defensible analyses
• Strong stakeholder management across Tax, Finance, Legal, and business leadership
• Hands-on, ownership mentality — comfortable driving detailed, repeatable processes (testing, true-ups, documentation refreshes)
• Clear, concise communication and the ability to coach partners through data, controls, and audit-ready narratives
Why Join
• Opportunity to work within a global EPC firm supporting large-scale international projects and complex intercompany operating models
• Exposure to complex transfer pricing issues across multiple jurisdictions, including documentation and audit defense
• High-ownership role with visibility to leadership, balancing strategic direction with hands-on delivery
• Collaborative environment with experienced leadership and external partners
TRS Staffing Solutions are an equal opportunities employer, and we welcome you to provide OFCCP data voluntarily here
We are an equal opportunity employer. All qualified individuals will receive consideration for employment without regard to race; color; age; sex; sexual orientation; gender identity; religion; national origin; disability; veteran status; genetic information; or any other criteria protected by governing law.
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