Transfer Pricing Manager

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Building cities. Driving commerce. Fueling Progress. For over 100 years Allison has powered the vehicles and technology that move our world forward.

What powers us Our employees. From the first person hired by James Allison in 1915 to the thousands across the globe who work for Allison today were driving progress everywhere because we employ top talent both the Allison Transmission and Allison Off-Highway Drive and Motion Systems business units our team strives to Improve the Way the World Works.

Learn more about this role and how you can begindriving your career forward!

Benefits:

The below list features some of the benefits currently available. Eligibility may be subject to the terms and conditions of governing documents and available benefits may be subject to change at the companys discretion.

• Choice of medical plans with prescription coverage

• Employer HSA contribution

• Dental & Vision Insurance

• Paid Parental Leave

• Short & Long-Term Disability

• Other voluntary benefits including: Critical Illness Hospital Indemnity Identity Theft Protection and Pet Insurance

• 401K with generous Company match & contribution

• Accrued Paid Time Off

• 12 Paid Holidays 1 Floating Holiday

• Robust employee wellness program

• Tuition assistance program

Job Description:

The Transfer Pricing Manager is a key role within Allisons tax team that includes responsibilities responsible for designing implementing and maintaining Allisons global transfer pricing framework. This includes implementing the transfer pricing coordinating global documentation managing TP audits and controversy and partnering closely with Finance Tax Legal and Business units to ensure that intercompany transactions are aligned with both business objectives and local regulatory requirements.

Key Responsibilities:

Transfer Pricing Strategy & Planning

Develop and refine transfer pricing policies consistent with the groups operating model value chain and business strategy.

Evaluate and advise on tax and transfer pricing implications of business restructurings supply chain changes and new business initiatives (e.g. new products manufacturing locations distribution models).

Provide technical transfer pricing insights to senior management to support informed decision-making.

Operational Implementation & Governance

Support the design and implementation of intercompany pricing models for tangible goods services IP and financing arrangements.

Translate transfer pricing policies into clear practical guidance and processes for Finance Accounting and Business teams.

Work with regional controllers and shared service centers to ensure accurate calculation booking and monitoring of intercompany charges (e.g. cost allocations royalties service fees mark-ups).

Develop and maintain robust governance including intercompany agreements documentation standards and control frameworks.

Monitor actual margins and results versus policy targets and recommend adjustments as needed.

Documentation & Compliance

Coordination of global transfer pricing documentation including Master File and Local Files and Country-by-Country Reporting (CbCR).

Oversee preparation and support for local transfer pricing forms disclosures and related tax return reporting.

Audit Management & Controversy

Assist controllers for transfer pricing inquiries from tax authorities across jurisdictions.

Manage transfer pricing audits information requests and dispute resolution working with external advisors where necessary.

Assess and quantify transfer pricing risks and exposures; recommend and implement mitigation strategies.

Support Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP) processes when appropriate.

Business Partnering & Cross-Functional Collaboration

Collaborate with Treasury Legal Operations and Commercial teams on new intercompany arrangements and business initiatives.

Provide training and guidance to Finance and Tax colleagues on transfer pricing policies changes in regulations and practical application.

Communicate complex transfer pricing concepts in a clear business-oriented manner to non-tax stakeholders.

Assess impacts of regulatory changes on Allison Transmissions transfer pricing model and recommend proactive responses

Key Performance Measures:

• Effective/timely management of compliance process

• Effective/timely communication with internal/external customers

• Problem solving ability and desire to improve current processes

Qualifications:

Bachelors degree in Accounting Finance Economics Business or related field.

Professional qualification such as CPA CTA or equivalent or advanced degree in Tax Economics or Finance.

Experience within the manufacturing automotive or industrial sectors.

Familiarity with ERP systems (e.g. SAP Oracle) and tax/TP software tools

Experience:

5 to 8 years of tax experience with at least 3 of dedicated transfer pricing experience ideally with a combination of Big Four/consulting and in-house multinational exposure.

Strong technical knowledge of U.S. transfer pricing regulation OECD Guidelines and key transfer pricing concepts (e.g. functional analysis comparability method selection DEMPE value chain analysis).

Hands-on experience reviewing transfer pricing documentation (Master File/Local File) and managing multi-jurisdiction compliance.

Proven experience with transfer pricing planning and implementation of intercompany policies across multiple entities and jurisdictions.

Demonstrated experience handling tax authority queries or audits in the transfer pricing area.

Advanced Excel skills and comfort working with financial data and modeling.

Excellent written and verbal communication skills with the ability to present complex issues clearly to senior management.

Allison Transmission is an equal opportunity employer. We have opportunities for all qualified applicants regardless of age race color sex religion creed national origin disability sexual orientation gender identity/expression or veteran status.

If you are an individual with a disability or a disabled veteran requiring assistance and/or reasonable accommodations reviewing any of the careers information please contact us at .

Please note that Allison Transmission will make an offer of employment only to individuals who have applied for a position using our official application. Be on alert for possible fraudulent offers of employment. Allison Transmission will not solicit money or banking information from applicants.