International Tax and Transfer Pricing Manager
As an International Tax and Transfer Pricing Manager you will advise Australian and multinational clients on complex international tax matters while leading and developing junior staff.
Key Responsibilities
Technical advisory and delivery
* Apply international tax and transfer pricing principles to cross‐border related‐party arrangements and multinational operating models.
* Navigate the international aspects of Australian taxation, including hybrid mismatch rules, controlled foreign company regimes, thin capitalisation rules, permanent establishment issues, withholding taxes and treaty interpretation.
* Provide integrated advice across Australian corporate tax and international tax, translating technical rules into commercially practical outcomes.
* Lead or support design and implementation of tax‐effective 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, policy design and documentation, benchmarking, economic analyses.
* Manage and review Country‐by‐Country reporting, master file, local file and other global transparency obligations, as well as GloBE Pillar Two reporting.
Project management and client engagement
* Manage end‐to‐end international tax and transfer pricing engagements: scoping, resourcing, budgeting, delivery and review.
* Act as primary day‐to‐day contact for clients, building trusted advisor relationships with tax, finance and legal stakeholders.
* Support Partners and Directors on complex engagements and proposals, and identify opportunities for additional services.
Controversy and risk management
* Assist clients with managing ATO risk reviews, audits and investigations, including transfer pricing and international tax reviews.
* Prepare technical position papers and ATO submissions and 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 and provide constructive feedback.
* Contribute to internal training on international tax, transfer pricing and Australian corporate tax fundamentals.
Business development and thought leadership
* Assist with proposals, pitch materials and client presentations.
* Contribute to internal and external thought leadership, including articles, alerts and technical updates.
* Support the growth and reputation of the International Tax and Transfer Pricing team.
About you
* Professional experience in international tax and/or transfer pricing within a professional services firm, tax authority or in‐house tax function.
* Strong foundation in Australian corporate tax with experience applying it to international structures.
* Demonstrated experience advising on CFCs, hybrid mismatches, thin capitalization and cross‐border structuring.
* Experience managing client relationships and a client‐service mindset.
* Strong analytical skills with proficiency in Excel and ability to work with financial data and models.
* Excellent written and verbal communication skills, able to explain complex technical issues clearly.
* High attention to detail, professional judgment and a collaborative approach within diverse teams.
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