Director of Transfer Pricing

The Director of Transfer Pricing is expected to be a key leader responsible for managing and operating a best-in-class global transfer pricing function, which will include policy implementation, planning and execution of strategic operational business models, integration of acquisitions into existing operational transfer pricing structures, participating in audit defense and dispute resolution, optimization of transfer pricing processes, and supporting compliance documentation. The Director of Transfer Pricing will work closely with global leaders across the organization including those in Finance, Treasury, Legal and other business functions.

Role Summary

The Director of Transfer Pricing will lead the enterprise-wide transfer pricing strategy for a large, publicly traded multinational organization. The Director of Transfer Pricing is expected to be a key leader responsible for managing and operating a best-in-class global transfer pricing function, which will include policy implementation, planning and execution of strategic operational business models, integration of acquisitions into existing operational transfer pricing structures, participating in audit defense and dispute resolution, optimization of transfer pricing processes, and supporting compliance documentation. The Director of Transfer Pricing will work closely with global leaders across the organization including those in Finance, Treasury, Legal and other business functions.

Responsibilities:

Transfer Pricing Strategy & Policy

• Design and implement the global transfer pricing framework covering tangible goods, services, IP, and financial transactions.
  
• Ensure intercompany pricing aligns with business substance and value creation across supply chains.
  
• Monitor global tax trends (Pillar One/Two, OECD BEPS developments, and local legislation) and advise on their strategic implications.
  
• Maintain clear policy governance and documentation standards across all jurisdictions.
  

Operational and Strategic Initiatives

• Partner with Finance, Operations, and Legal to structure business models that achieve both commercial and tax optimization.
  
• Support large-scale supply chain transformations, principal structures, and shared service center models.
  
• Evaluate cash tax impacts and financial statement effects of transfer pricing design.
  
• Collaborate on intellectual property planning, cost sharing, and valuation analyses.
  

Mergers, Acquisitions, and Business Transformation

• Lead transfer pricing diligence, risk assessment, and structuring efforts for acquisitions and divestitures.
  
• Develop integration and policy harmonization strategies for newly acquired entities.
  
• Support IP migration and valuation projects tied to business development initiatives.
  

Audit, Controversy, and Risk Management

• Direct the company's global transfer pricing audit defense strategy.
  
• Oversee the preparation of documentation, manage regulatory inquiries, and lead engagement with tax authorities.
  
• Coordinate Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) requests.
  
• Proactively identify emerging controversy risks and establish mitigation frameworks.
  

Compliance and Reporting

• Oversee timely preparation of Master Files, Local Files, and intercompany agreements consistent with OECD and local regulations.
  
• Partner with tax reporting and accounting teams on FIN 48 and uncertain tax position analyses.
  
• Drive process automation and data quality improvements in intercompany transaction flows.
  

Leadership and Collaboration

• Lead and develop a global team of transfer pricing professionals and external advisors.
  
• Communicate complex technical concepts clearly to executive-level stakeholders.
  
• Foster cross-functional collaboration with Finance, Legal, and Operations to ensure alignment between business decisions and tax policies.
  

Qualifications

Education & Credentials

• Bachelor's degree in Accounting, Economics, Finance, or a related field required.
  
• Advanced degree (MBA, MS Tax, JD, or PhD) preferred.
  
• CPA, JD, or equivalent certification a plus.
  

Experience

• 12-15+ years of progressive transfer pricing experience in multinational corporations or Big Four advisory firms.
  
• Proven leadership experience managing global teams and multi-jurisdictional operations.
  
• Demonstrated expertise in IP planning, cost sharing, and valuation.
  
• Track record managing complex audits, APAs, or MAPs.
  
• Experience integrating transfer pricing processes post-M&A preferred.
  

Skills & Attributes

• Deep knowledge of OECD Guidelines, BEPS, and international tax regulations.
  
• Strong economic, analytical, and financial modeling skills.
  
• Strategic thinker with the ability to balance technical precision and practical solutions.
  
• Excellent communication and presentation skills.
  
• Skilled in tools such as Excel, Power BI, Alteryx, or similar data automation platforms.
  

Our Company:

Axalta has remained at the forefront of the coatings indu