Transfer Pricing Manager/Senior Manager

Overview of Firm
PKF is the 12th largest accountancy brand and the 12th largest audit practice in the UK. We are also an active member of PKF Global, an international network of legally independent accounting firms that gives us an on the ground presence in 150 countries around the world with access to more than 20,000 people across 440 offices globally.

We provide a full range of audit, accountancy, tax and advisory services, and are experts at simplifying complexity. We are particularly well-known for working with complex clients with challenging issues in fast-moving and highly technical areas, such as the insurance industry, the global capital markets and the not for profit sector. Our aim is to understand people, the organisations they run, and what matters to them, so we can simplify complexity and help them achieve their ambitions.

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Introduction to the Division
Tax
The division provides VAT, Corporate Tax, Transfer Pricing, Personal Tax, Global Mobility and Employment Tax compliance and advisory services to a wide range of clients and prides itself on the quality of service, high degree of professionalism and personal approach that is offered to each and every client.

The division has a growing number of Corporate Clients, with the team regularly involved in a number of transactional pieces of advisory work, across a variety of sectors and covering a variety of taxation issues. These can impact both the company and individuals, for example, demergers, restructuring, acquisitions and disposals.

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*Responsibilities
Purpose and aim of the role*
The role requires an ambitious, confident individual, with a strong academic background to join the growing Corporate Tax Team as a Transfer Pricing Manager/Senior Manager. The appropriate grade will be subject to relevant skills and experience.

The successful candidate will be a member of the Team, responsible for assisting the Transfer Pricing Director and Corporate Tax Partners in servicing clients, covering the complete cycle of transfer pricing advisory and compliance work.

The candidate will take ownership of the delivery of transfer pricing services and delegating work to the more junior people within the team. This role is London based.

Transfer Pricing Projects Can Involve

• Planning and design of transfer pricing policies for all transaction types (including tangible goods, services, intellectual property and financing) covering various business operating models
• Preparation and review of transfer pricing documentation including benchmarking studies e.g. Master Files, Local Files and Country-by-Country Reporting
• Review and guidance on implementation of transfer pricing policies e.g. financial and operational testing of policies, comment on agreements prepared by legal advisors
• Review of intercompany financing arrangements
• Thin capitalisation reviews
• Transfer pricing risk reviews of cross-border operations and remediation advice
• Advance Pricing Agreement and Mutual Agreement Procedure cases
• Dispute resolution with tax authorities
• Awareness of broader tax considerations of transfer pricing policies and cross-border operations e.g. withholding taxes, VAT/customs duties and permanent establishment risks

The team has an entrepreneurial culture and offers accelerated learning with high exposure to project management and client relationships. Training and coaching will be provided to support ongoing professional development.

The team is growing and promotion opportunities will be available in the future for a successful and ambitious candidate.

Client
Responsibilities****
The tax team deals with a broad range of transfer pricing advisory and compliance work, emanating from a wide variety of clients.

Key
Responsibilities
To Be Carried Out Are

• Liaison with the wider tax team, tax audit and accounting teams and other service lines in respect of upcoming work and delivery timetable
• Management of deadlines in a timely manner in respect of client work allocation
• Build and maintain relationships with clients and provide high levels of client service
• Manage WIP and billing for own clients, ensuring commercial recoveries
• Management of more junior members of the team to deliver work and provision of feedback
• Responsibility for adherence with the firm's risk management procedures and some administrative tasks

Special work/ad hoc assignments

Work May Include The Following

• Tender proposals
• Tax audit support
• Due diligence support
• Opportunities to train staff on transfer pricing matters
• Defence and resolution of tax authority enquiries
• Liaison with PKF International
• Assistance in team and firm marketing initiatives

People Management
The post-holder will be responsible for managing junior staff and may have the opportunity to manage some direct reports following successful completion of probation.

PKF Littlejohn believes strongly in encouraging the personal development of each member of staff and the firm supports and provides internal and external training courses as well as professional updates on technical and non-technical subjects. In addition to managing their own development, individuals are expected to encourage and take an active role in the training and development of junior staff.

Opportunities
Career progression at PKF Littlejohn is meritocratic. The tax division is growing; there is therefore ample scope for progression. Career progression is reviewed at the annual appraisal.

Person Specification

• Proven skills and experience in transfer pricing gained in practice and/or industry
• A good understanding of the OECD Transfer Pricing Guidelines
• Able to explain complex issues in a way non-tax specialists can clearly understand
• Up-to-date technical skills and experience, across a broad range of businesses
• Ability to manage work within budgets and deadlines
• Good report writing skills (including Master Files, Local Files and specialist input into due diligence and tax audit reports)
• Ability to build relationships with clients, colleagues and across PKF International