Careers
Careers in transfer pricing
Transfer pricing sits between tax law, economics and accounting. The work is part forensic — understanding how a business actually makes money — and part evidential: writing down that understanding so it survives an examination five years later.
What the job actually involves
Understanding the business
Interviewing operational people about who decides what, who takes the risk, and who owns what. Most of the technical answer follows from this.
Building the evidence
Benchmarking, segmentation, valuation and reconciliation. Detail-heavy work where accuracy is non-negotiable.
Writing the position
Documentation that a stranger with an adversarial mindset will read years later. Clear writing is a technical skill here.
Defending it
Audit responses, MAP and APA negotiation. Persuasion within a legal framework, usually over multi-year timelines.
How careers progress
- Analyst / Associate 0–2 years
- Benchmarking searches, local file drafting, segmented P&L reconciliation, transaction inventories.
- Consultant / Senior 2–5 years
- Functional analysis interviews, method selection memos, year-end adjustment models, first drafts of audit responses.
- Manager 5–9 years
- Owning documentation cycles across countries, restructuring projects, APA applications, review and coaching.
- Director / Head of TP 9+ years
- Policy design, controversy strategy, board and audit committee reporting, competent authority negotiation.
Skill that matters: Excel fluency and precision. You will be judged on whether your numbers tie.
Skill that matters: Writing. The ability to explain a position clearly is what gets you in front of clients.
Skill that matters: Project management and knowing when to escalate a technical judgement.
Skill that matters: Commercial judgement — deciding what risk to accept, not just how to describe it.
Knowledge check
Five questions from the terms in this glossary. Answers explain themselves as you go.
01A subsidiary holds legal title to a patent but has no employees and cannot evaluate R&D projects it funds. What return is it generally entitled to?
02Which method is normally the most reliable where a genuinely comparable internal third-party transaction exists?
03A tested party's margin falls below the interquartile range. In most jurisdictions, where is the adjustment made to?
04What is the primary purpose of a country-by-country report?
05An adjustment is proposed in one country and the taxpayer wants relief from double taxation. What preserves treaty access?
Where to start reading
Four terms cover most of what a first interview will test.
Book a TP Health Check
Unsure how your transfer pricing would hold up?
A fixed-scope review of your intercompany pricing, documentation and audit exposure — scoped to your jurisdictions, delivered as a written risk memo. First response within one business day.