Transfer Pricing Jobs in Tennessee

We're tracking 3 live transfer pricing roles in Tennessee.

Live roles

3

Not enough pay data yet — salary snapshot appears once more roles report bands.

Seniority spread

  • Director/Head of Tax
    1
  • Manager
    1
  • Senior/Assistant Manager
    1

Active opportunities

3 live · updated hourly
CB

Director Tax

Cracker BarrelLebanon, Tennessee, United States$175k – $235kAI est.
Posted 30+ days ago
Hilton logo

Manager Tax Planning

HiltonMemphis, TN, United States$90k – $130k
Posted 30+ days ago
Hilton logo

Senior Analyst Tax Planning

HiltonMemphis, TN, United States$68k – $95k
Posted 30+ days ago

About this market

Market context

Transfer pricing in the Tennessee context refers to the pricing of transactions between related entities for goods, services, or intellectual property, primarily impacting how income and expenses are reported for Tennessee corporate franchise and excise tax purposes. Although there are no specific state transfer pricing rules, the federal arm's length standard influences how multinational corporations allocate income that ultimately flows through to state tax filings.

Tennessee levies a Franchise Tax based on net worth (or the book value of real & tangible property in TN, whichever is greater) and an Excise Tax on net earnings at a rate of 6.5%. The proper allocation of intercompany charges can significantly affect the Tennessee apportioned income. While there is no specific Tennessee transfer pricing regime, the Tennessee Department of Revenue (TDOR) expects taxpayers to comply with federal income tax rules, including IRC Section 482 for intercompany transactions, when determining taxable income subject to apportionment. Non-arm's length transactions can lead to adjustments impacting the state's tax base.

What's driving demand

  • Federal Transfer Pricing Compliance
  • Multistate Corporate Expansion
  • Increased Scrutiny on Intercompany Transactions
  • Apportionment Issues for Multistate Businesses

Regulatory timeline

  • 2023-01-01Tennessee Department of Revenue General Taxpayer InformationOngoing
    source

Credentials that matter

  • CPA (Certified Public Accountant)essential
  • MST (Master of Science in Taxation)valued
  • JD (Juris Doctor)valued

Skills & tools

IRC Section 482 RegulationsOECD Transfer Pricing GuidelinesEconomic AnalysisFinancial ModelingTax Provision (ASC 740)Microsoft ExcelAlteryxTax Research Software (e.g., Bloomberg Tax, CCH Axcess)

Frequently asked

What is transfer pricing in Tennessee?
Transfer pricing in the Tennessee context refers to the pricing of transactions between related entities for goods, services, or intellectual property, primarily impacting how income and expenses are reported for Tennessee corporate franchise and excise tax purposes. Although there are no specific state transfer pricing rules, the federal arm's length standard influences how multinational corporations allocate income that ultimately flows through to state tax filings.
How does transfer pricing work in Tennessee?
Tennessee levies a Franchise Tax based on net worth (or the book value of real & tangible property in TN, whichever is greater) and an Excise Tax on net earnings at a rate of 6.5%. The proper allocation of intercompany charges can significantly affect the Tennessee apportioned income. While there is no specific Tennessee transfer pricing regime, the Tennessee Department of Revenue (TDOR) expects taxpayers to comply with federal income tax rules, including IRC Section 482 for intercompany transactions, when determining taxable income subject to apportionment. Non-arm's length transactions can lead to adjustments impacting the state's tax base.
What credentials matter for Tennessee Transfer Pricing roles?
Employers most often look for: CPA (Certified Public Accountant), JD (Juris Doctor), MST (Master of Science in Taxation).
Which tools and systems appear in Tennessee Transfer Pricing job specs?
Commonly cited: IRC Section 482 Regulations, OECD Transfer Pricing Guidelines, Economic Analysis, Financial Modeling, Tax Provision (ASC 740), Microsoft Excel, Alteryx, Tax Research Software (e.g., Bloomberg Tax, CCH Axcess).
How many Tennessee Transfer Pricing roles are live right now?
3 live roles on taxjobs.ai.