Senior Manager – Transfer Pricing

Role Overview

• Lead transfer pricing engagements from scoping through delivery, covering documentation, policy design, intercompany structuring, and HMRC defence
• Advise on the tax and commercial implications of cross-border transactions, including leverage and deductibility in PE-backed structures
• Identify and manage transfer pricing risks in fast-moving transaction environments, coordinating across deal and tax workstreams
• Prepare and negotiate Advance Pricing Agreements and support clients through audits and enquiries
• Manage compliance deliverables including CTSA documentation and OECD-aligned local file and master file requirements
• Build and maintain trusted relationships with senior client stakeholders, including CFOs, tax directors, and PE finance teams
• Use AI and automation tools in the delivery of analysis and documentation — we expect our people to work smarter, not just harder
• Mentor and develop junior team members, providing clear direction and quality feedback on their work
• Contribute to business development by identifying opportunities within existing clients and supporting targeted outreach

Requirements

• ACA, CTA, or equivalent qualification, or demonstrable experience at Senior Manager level in transfer pricing
• Solid grounding in UK and international transfer pricing regulations, OECD guidelines, and BEPS
• Experience advising PE-backed or high-growth businesses, with an understanding of financing structures, leverage, and cross-border tax considerations
• A track record of managing client engagements end-to-end, including financial and risk management
• Strong commercial instincts — you understand what clients actually need and you know how to deliver it clearly
• Proven ability to build relationships with senior stakeholders and communicate complex technical positions in plain language
• Comfort working in a fast-paced, project-based environment with multiple concurrent engagements
• Genuine interest in technology and AI-enabled ways of working — we want people who are curious about how tools can make advice sharper and faster

Benefits

• Hybrid and flexible
• Inclusion and accessible recruitment process