Group Transfer Pricing Manager (gn)

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Job Title: Group Transfer Pricing Manager (gn)

Location: Lisbon, Portugal

Reports To: Head of Tax Compliance

Type: Full-Time

Responsible for developing, operationalizing, and managing transfer pricing policies across the global organization. This role plays a key part in ensuring that all intra-group transactions meet both business objectives and conform to legislative requirements in a dynamic, multi-jurisdictional environment. The successful candidate will work closely with cross-functional teams, including finance, actuarial, reinsurance purchase and operations, to drive effective transfer pricing compliance and support business growth.

• Manage the group’s global transfer pricing policies and procedures, ensuring alignment with the corporate strategy and evolving international regulations.
• Work with subject matter experts to design and execute transfer pricing approach for a wide range of intra-group transactions, including reinsurance, shared services, management fees, intellectual property, and financing arrangements.
• Manage the regular review and update of transfer pricing documentation, methodologies, and frameworks to reflect changes in business operations, regulatory requirements, and best practices.
• Provide strategic advice on transfer pricing implications of new products, business initiatives, and cross-border transactions.

• Ensure full compliance with OECD guidelines, local transfer pricing regulations, and other relevant legislation across all jurisdictions in which the group operates.
• Monitor and interpret global regulatory developments, proactively assessing and communicating potential impacts to internal stakeholders.

• Coordinate the preparation and maintenance of contemporaneous transfer pricing documentation, including Master Files, Local Files, and Country-by-Country Reports, including benchmarking studies, comparability analyses, and economic assessments to support transfer pricing positions.

• Work in partnership with actuarial, finance, and business teams to ensure accurate pricing of internal transactions.
• Design and maintain controls to ensure transfer pricing operational effectiveness.

• Develop and maintain robust governance frameworks for transfer pricing, including internal controls, risk management, and compliance monitoring.
• Support the negotiation and implementation of Advance Pricing Agreements (APAs) and the resolution of transfer pricing disputes with tax authorities.
• Coordinate responses to internal and external audit requests relating to transfer pricing, ensuring transparency and timely resolution of issues.
• Identify, assess, and mitigate transfer pricing risks across the group, providing proactive solutions and escalating concerns as necessary.
• Design and deliver training programs to increase understanding of transfer pricing principles and requirements among relevant staff.
• Maintain up-to-date knowledge of global transfer pricing trends, regulations, and emerging issues, disseminating insights to key stakeholders.

• Act as the primary point of contact for transfer pricing subject matter expertise.
• Work within a team of tax professional to foster an environment of learning, innovation, continuous improvement and operational excellence.
• Manage relationships with external advisors and auditors on transfer pricing issues, documentation, and audits.
• Work with advisors and senior stakeholders to manage relationships with tax authorities on transfer pricing matters.

• Advanced degree (or equivalent certification) in Taxation, Accounting, Finance, or related field.
• Minimum 7 years of progressive experience in transfer pricing or a related discipline within a multinational organization or Big Four firm, insurance industry background preferred.
• Demonstrable expertise in transfer pricing with a deep understanding of relevant regulations and operating models.
• Proven track record of successfully delivering transfer pricing documentation, compliance, and audit defence in multiple jurisdictions.
• Strong analytical and quantitative skills, with the ability to interpret complex data and communicate insights clearly to a non-technical audience.
• Proven capability in managing projects, driving cross-functional collaboration and influencing stakeholders at all levels of an organization.
• Excellent written and verbal communication skills, with fluency in English; additional languages are an asset.
• High level of integrity and professionalism, with a commitment to ethical practices and corporate governance.

• Technical Expertise: In-depth understanding of transfer pricing methods, OECD guidelines, BEPS action items, and local regulations applicable to insurance and financial services.
• Strategic Thinking: Ability to anticipate the impact of regulatory changes and business developments, translating them into actionable policies and strategies.
• Analytical Acumen: Advanced problem-solving capabilities, with the skill to analyze complex interconnected financial and tax issues.
• Collaboration: Excellent interpersonal skills with the ability to foster partnerships across departments, geographies, and external entities.
• Communication: Ability to simplify and articulate technical concepts for non-specialist audiences, building trust and credibility with diverse stakeholders.
• Change Management: Experience navigating through organizational change and influencing outcomes in an evolving regulatory environment.
• Ethics and Integrity: Commitment to upholding the highest standards of ethics and integrity in all tax-related matters.

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