Transfer Pricing Senior Manager

Job Title

• Transfer Pricing Senior Manager

Contract Type

Time Type

Job Description

• The Transfer Pricing Senior Manager is responsible for overseeing and managing
• the company's transfer pricing policies, documentation, and compliance across
• all jurisdictions. This role involves developing and implementing transfer
• pricing strategies, ensuring adherence to international regulations, and
• supporting audits and disputes related to transfer pricing matters.

Role Summary

• Based in our offices in Madrid (alternatively Amsterdam) and reporting directly
• to our Global Head of Taxes, the Transfer Pricing Senior Manager is responsible
• for overseeing and managing the company's transfer pricing policies,
• documentation, and compliance across all jurisdictions. This role involves
• developing and implementing transfer pricing strategies, ensuring adherence to
• international regulations, and supporting audits and disputes related to
• transfer pricing matters.

• Main Responsilibities

• Strategic & Advisory Responsibilities

• Develop and continuously refine the Group’s transfer pricing strategy in

alignment with evolving business models (trading, assets, shipping, GBS, new

geographies).

• Provide expert advice to the Global Head of Taxes and senior business

stakeholders on TP implications of new ventures, restructurings, M&A, and

intra‑group financing.

• Lead the annual global TP planning cycle, including profit allocation models,

pricing policy refreshes, and adjustments to intercompany flows.

Operational & Compliance Responsibilities

• Oversee end‑to‑end preparation of Master File, Local Files, CBCR,

transactional reports, and benchmarking studies across all jurisdictions.

• Ensure timely and accurate implementation of intercompany agreements (ICAs),

including monitoring consistency between legal terms and actual conduct.

• Review and validate monthly and quarterly transfer pricing calculations

(profit splits, margin testing, CUP analyses, trader remuneration mechanisms,

etc.).

• Maintain and update the TP control framework integrated within the Group’s

Internal Control over Financial Reporting (ICFR).

Audit, Risk Management & Disputes

• Serve as the primary contact for TP audits globally; prepare defense files,

respond to tax authority inquiries, and manage dispute resolution strategies.

• Coordinate with external advisors and internal teams to minimize tax

controversy risk through proactive documentation and robust modelling.

• Monitor global TP regulatory changes (OECD, EU, UN, local tax authorities)

and assess their impact on Group’s model.

Cross-Functional Collaboration

• Work closely with Trading, Legal, Controlling, Accounting, and Finance to

embed transfer pricing requirements into processes and decisions.

• Support the integration of new markets and entities into Group’s TP model

(e.g., expansion into Africa, Eastern Europe, assets strategy).

Data, Analytics & Process Improvement

• Enhance the use of data analytics and Power BI dashboards for monitoring

margins, intercompany flows, and TP KPIs.

• Lead continuous improvement initiatives to streamline and automate TP

calculations, documentation workflows, and risk monitoring.

People Development & Knowledge Building

• Train finance and accounting teams globally on TP concepts, implementation

practices, and compliance expectations.

• Mentor junior tax and controlling staff (even without formal managerial

responsibility).

Profile

• CPA, ACCA, CA, or equivalent accounti/taxing certification.
• Preferred: Master’s degree in Taxation, Finance, Economics, or related field.
• 5-7 years of transfer pricing experience (Big 4, multinational trading/energy

company, or complex global MNE).

• Strong exposure to trading environments, commodities, or supply‑chain‑heavy

businesses is a significant advantage.

• Experience managing or coordinating TP audits and dispute resolution in

multiple jurisdictions.

• Deep understanding of OECD TP Guidelines, BEPS, EU/J5 initiatives, and local

statutory requirements.

• Advanced financial modelling skills; ability to interpret complex business

flows and translate them into TP models.

• Strong command of IFRS and local GAAP interactions with transfer pricing.
• Experience designing and maintaining profit split methodologies, TNMM

benchmarking, and economic analyses.

• High proficiency in MS Excel, Power BI, and data tools used for transactional

analysis.

• Strategic, analytical, and structured thinker with an ability to simplify

complexity.

• High degree of autonomy, judgment, and accountability in a fast‑paced,

high‑stakes environment.

• Strong influencing skills; able to communicate effectively with traders,

senior finance leaders, auditors, and authorities.

• Project leadership abilities, including managing multiple jurisdictions and

external advisors.

• Excellent oral and written skills in English.

If you think the open position you see is right for you, we encourage you to

apply!

Our people make all the difference in our success.