About the role:
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.
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