Transfer Pricing Tax Manager Job at Freudenberg North America Limited Partnership, Plymouth, MI

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  • Freudenberg North America Limited Partnership
  • Plymouth, MI

Job Description

Responsibilities arrow_right

  • Collaborate with North American business group leaders and global transfer pricing team to co-develop transfer pricing strategies, objectives, and policies for the North America Region (aligned with global initiatives)
  • Educate business group controllers about transfer pricing considerations and best practices
  • Lead research and prepare expert opinions on a broad range of transfer pricing and international tax matters, including cross-border transactions
  • Develop, implement and document BEPS-compliant transfer pricing­ systems to identify, ringfence, and proactively implement measures to mitigate transfer pricing risk
  • Oversee the timely and accurate completion of transfer pricing documentation (i.e. local and master files) and adhere to regulatory requirements (i.e. statutory notifications and declarations) for US and Canadian operations
  • Oversee outside transfer pricing service providers for Mexican and Costa Rican affiliates and support local tax team with transfer pricing matters
  • Summarize status of local file documentation, quantify potential risks and recommend mitigating strategies
  • Engage with outside service providers for transfer pricing technical support, benchmarking studies, and local file preparation assistance when necessary
  • Team with business group controllers to drive proper accounting and periodic monitoring of operating margins and I/C pricing adjustments when necessary
  • Collaborate with legal, tax, and global transfer pricing teams to proactively address transfer pricing audits and controversy
  • Training and co-oversight of shared service center team assisting with preparation of routine local files
  • Support US and Canadian tax compliance reporting related to transfer pricing, including but not limited to Form 5472, T-106, CbC and similar Pillar 2 intercompany transaction reporting requirements
  • Participate in the preparation of intra-group contracts where transfer pricing arrangements are particularly relevant
  • Support in matters relating to the assessment, declaration and taxation of permanent establishments
  • Review double tax-treaties between the US and other jurisdictions and determine the applicability of such treaty on a transfer pricing matter / transaction
  • Support the regional year-end tax provision process during the annual financial statement close

Qualifications arrow_right

  • Master's degree in accounting, finance, economics, or business
  • 6+ years of combined Transfer Pricing and International Tax experience from a national or regional public accounting firm, or Fortune 500 company
  • Familiarity transfer pricing reporting tool or similar platforms preferred (PWC globalDoc, Thomson Reuters onesource, etc)
  • Transfer pricing regulatory experience using BNA/RIA/IBFD or similar databases
  • Strong analytical and data interpretation skills
  • Travel Requirements: Travel to Freudenberg sites across the United States, normally up to 10%; occasional/annual international travel to Germany likely

Job Tags

Permanent employment, Local area,

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