Transfer Pricing Director - Financial Transactions

About the role

PwC Canada is hiring a Transfer Pricing Director focused on financial transactions in Toronto. The role sits within the Transfer Pricing and Customs practice, which advises multinational clients on transfer pricing, customs valuation, trade compliance and international tax planning. You will lead financial transactions transfer pricing projects, mainly complex intercompany financing matters, and work closely with tax, treasury, valuation and legal colleagues.

Key responsibilities

• Lead and manage financial transactions transfer pricing projects, including intercompany loan pricing, debt capacity analyses, guarantee fee analyses, cash pooling arrangements and related documentation
• Oversee multiple client engagements, ensuring quality and timely delivery
• Develop economic analyses covering credit risk, capital markets data, borrower and lender perspectives and commercial terms of related-party financing
• Prepare and review technical memoranda, transfer pricing reports and client deliverables
• Advise clients on transfer pricing planning, controversy and audit defence matters
• Build client relationships by understanding their businesses, treasury policies and financing structures
• Use financial data, market evidence and technology-enabled tools to build defensible analyses
• Explore emerging technologies such as artificial intelligence and guide the team in using them
• Collaborate with PwC tax, valuation and international network teams
• Coach and develop team members, contribute to business development and uphold the firm's code of ethics

Required profile

• Demonstrated Director-level transfer pricing experience, with significant experience on financial transactions and intercompany financing
• MBA, MA or advanced degree in Economics, Tax, Finance or Business Administration, or an equivalent combination of education and experience
• Strong research, writing and quantitative analytical skills
• Ability to explain complex financial and economic concepts clearly to clients, tax authorities and internal stakeholders
• Ability to coach and retain a team of tax professionals
• CFA or CPA designation is a strong asset

Required skills

• Arm's length interest rate setting, credit ratings and credit risk
• Debt capacity, guarantees, cash pooling and capital structure considerations
• Financial modeling and financial statement analysis
• International taxation and BEPS

The salary range is $152,000 - $202,000, with possible variable incentive pay. The position follows the departure of a valued team member.