Manager - International Tax and Transfer Pricing

OUR VALUE PROPOSITION

At RSM, our purpose is to instill confidence in a world of change for both our

clients and our people.

RSM Australia supports a people-centric and collaborative culture where we are

committed to empowering and developing you. As a leading professional services

firm, we connect you to an extensive network of global resources and invest in

your future. We value the meaningful work that you do and encourage you to be a

part of the change.

Our value proposition is our commitment to you; it highlights the experiences,

benefits, and value that you can expect as part of RSM. This is underpinned by

our three values – integrity in everything that we do, supporting clients

everywhere, and developing and valuing everyone.

Who we are

• RSM Australia is a member of RSM, the world’s 6th largest network of audit, tax
• and consulting firms. We are an award-winning professional services firm with
• over 100 years experience supporting Australian businesses. We believe in
• putting people first and we are proud to have developed a work culture that
• fosters growth, collaboration and success.

About the role

• RSM have recently been named amongst the top 10 best places to work in the 2025

Financial Review. Are you looking for a great company? We are hiring!

As an International Tax and Transfer Pricing Manager at RSM you will consult

with clients and provide advice on a range of International Tax and Transfer

Pricing matters and manage a team of juniors

Position Summary

• As a Manager in the International Tax and Transfer Pricing, you will play a key
• role in advising Australian and multinational clients on the complex
• international aspects of Australian taxation. The role combines deep technical
• delivery with strong client engagement and people leadership, spanning
• international tax structuring, cross‑border transactions, transfer pricing, and
• global tax reporting obligations. You will work closely with Partners and
• Directors to deliver practical, technically robust advice on inbound and
• outbound investment structures, financing arrangements, and supply chain models.
• You will also manage and develop junior team members and contribute to the
• growth of the firm’s international tax and transfer pricing capability through
• thought leadership, business development, and technology initiatives.

Key Responsibilities

• Technical advisory and delivery

• Apply complex international tax and transfer pricing principles to advise

clients on cross‑border related‑party arrangements and multinational

operating models.

• Assist clients in navigating the international aspects of Australian

taxation, including

• Hybrid mismatch rules

• Controlled Foreign Company (CFC) regimes

• Thin capitalisation and debt/equity rules

• Permanent establishment issues

• Withholding taxes and treaty interpretation

• International tax structuring and planning for inbound and outbound groups

• Provide integrated advice across Australian corporate tax and international

tax, translating technical rules into commercially practical outcomes.

• Lead or support the design and implementation of tax‑effective international

and transfer pricing structures, including principal models, financing

arrangements, IP structures and global supply chains.

• Apply OECD Guidelines and Australian transfer pricing rules to:

• Functional and value chain analyses

• Transfer pricing policy design and documentation

• Benchmarking and economic analyses

• Manage and review complex Country‑by‑Country (CbC) reporting, master file,

local file and other global transparency obligations.

• Manage and review GloBE Pillar Two reporting obligations.

Project management and client engagement

• Manage end‑to‑end international tax and transfer pricing engagements,

including scoping, resourcing, budgeting, delivery and review.

• Act as a primary day‑to‑day contact for clients, building trusted advisor

relationships with tax, finance, and legal stakeholders.

• Support Partners and Directors on large, technically complex engagements and

proposals.

• Identify opportunities to provide additional services to clients,

collaborating across tax and advisory teams.

Controversy and risk management

• Assist clients with managing ATO risk reviews, reviews, and audits,

including

• Transfer pricing reviews and audits

• International tax risk reviews

• Preparation of technical position papers and ATO submissions

• Support dispute resolution strategies, including engagement with ATO

specialists.

People leadership and development

• Lead, coach and mentor junior team members, fostering technical development

and high‑quality client delivery.

• Review work prepared by junior staff, providing clear, constructive feedback.

• Contribute to internal training on international tax, transfer pricing, and

Australian corporate tax fundamentals.

Business development and thought leadership

• Assist with the preparation of proposals, pitch materials, and client

presentations.

• Contribute to internal and external thought leadership, including articles,

alerts and technical updates on international tax and transfer pricing

developments.

• Support the growth and reputation of the International Tax and Transfer

Pricing team in the market.

About you

• Professional experience in international tax and/or transfer pricing within a

professional services firm, revenue authority, or in‑house tax function.

• Strong foundation knowledge of Australian corporate tax, with experience

applying that knowledge to international structures and transactions.

• Demonstrated experience advising on international tax concepts such as CFCs,

hybrid mismatches, thin capitalization, and cross‑border structuring.

• Experience in managing relationships with clients and a client service

mindset

• Strong analytical skills, including the ability to work with financial data

and models (Excel proficiency expected).

• Excellent written and verbal communication skills, with the ability to

explain complex technical issues clearly to clients.

• High attention to detail, professional judgement, and a collaborative

approach to working within diverse teams.

Life at RSM

• RSM provides a great environment to build skills and confidence and we help our
• people achieve their best. We are trusted advisors to our clients, so it is
• critical for us to find the right people for the job on offer. Our network of
• offices across Australia and around the world allow us to offer a personal
• service to all our clients regardless of where they are!

• Working for RSM entitles everyone to a wide range of leading health, wellness
• financial and lifestyle benefits.

How to apply

• Please click on the “apply” button and complete our online application form.

• Agencies, thank you for thinking of us, but our recruitment is managed
• internally, and we will reach out to our preferred suppliers if we need
• assistance.