Transfer Pricing - Financial Transactions, Director

PwC Canada; Toronto; On-site; CAD 152,000 - 202,000; Full time

Job summary

PwC Canada is seeking a senior-level transfer pricing professional to lead financial transactions TP projects, including intercompany loan pricing and debt capacity analyses, for multinational clients in Canada. You will oversee multiple engagements, develop robust economic analyses, and prepare technical memoranda while advising on planning and audit defence related to intercompany financing.

You will collaborate with tax, valuation and legal teams, coach junior staff, contribute to business

Qualifications

• Demonstrated director-level transfer pricing experience, advising on financial transactions and intercompany financing.
• Strong knowledge of arm’s length interest rate setting, credit risk, debt capacity, guarantees, cash pooling and capital structure considerations.
• MBA/MA or advanced degree in Economics/Tax/Finance/Business Administration or equivalent experience.

Responsibilities

• Lead and manage financial transactions transfer pricing projects, including intercompany loan pricing and debt capacity analyses.
• Oversee multiple client engagements, ensuring quality and timely delivery.
• Develop robust economic analyses using market data, borrower/lender perspectives and related-party financing terms.
• Prepare and review technical memoranda and transfer pricing reports with clear methodologies and conclusions.
• Advise clients on transfer pricing planning, controversy and audit defence matters.
• Build and grow client relationships by understanding clients’ treasury policies and financing structures.

Skills

Transfer pricing

Intercompany financing

Credit risk analysis

Client relationship mgmt

Leadership

Project management

Education

CFA designation

CPA designation

MBA or advanced degree

Job description

A career within our Transfer Pricing & Customs practice will provide you with the opportunity to help multinational clients navigate complex cross-border tax, trade and financing matters. Our team advises clients on transfer pricing, customs valuation, trade compliance and international tax planning, helping them achieve compliant, commercially sound outcomes aligned with evolving global regulatory expectations. In this role, you will focus on financial transactions transfer pricing, including interest rate analyses, debt capacity, cash pooling, guarantees, hedging, providing services related to documentation, planning and dispute resolution matters. You will primarily support complex intercompany financing projects and collaborate closely with tax, treasury, valuation and legal stakeholders. Driven by curiosity, you are a reliable, contributing member of a team. In our fast-paced environment, you are expected to adapt to working with a variety of clients and team members, each presenting varying challenges and scopes. Every experience is an opportunity to learn and grow. You are expected to take ownership and consistently deliver quality work that drives value for our clients and success as a team. As you navigate through the Firm, you build a brand for yourself, opening doors to more opportunities.

The opportunity

• 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 robust economic analyses that consider credit risk, capital markets data, borrower and lender perspectives, and the commercial terms of related-party financing arrangements
• Prepare and review technical memoranda, transfer pricing reports and client deliverables that clearly explain methodologies, assumptions, conclusions and supporting evidence
• Advise clients on transfer pricing planning, controversy, and audit defence matters involving intercompany financing transactions
• Build and grow client relationships by understanding clients’ businesses, treasury policies, financing structures and broader tax objectives
• Use financial data, market evidence and technology-enabled tools to develop efficient, defensible and insightful analyses
• Explore and embrace emerging technologies, including artificial intelligence, and guide the team in incorporating these tools to enhance the quality and efficiency of client service delivery
• Collaborate with PwC tax, valuation and international network teams to deliver integrated advice on complex cross-border financing issues
• Guide, coach and develop team members by providing clear direction, technical guidance and timely feedback on financial transactions transfer pricing work
• Contribute to business development by identifying client needs, supporting proposals and helping market financial transactions transfer pricing services to existing and prospective clients
• Uphold the firm’s code of ethics and business conduct

What You’ll Bring

• Demonstrated experience in transfer pricing at the Director level, with significant experience advising on financial transactions and intercompany financing arrangements:
• Strong knowledge of financial transactions transfer pricing concepts, including arm’s length interest rate setting, credit ratings, credit risk, debt capacity, guarantees, cash pooling and capital structure considerations
• The CFA or CPA designation is a strong asset
• MBA, MA or advanced degree in Economics, Tax, Finance or Business Administration, or an equivalent combination of education and professional experience
• Strong research, writing and quantitative analytical skills, with comfort working with detailed financial analysis, capital markets data and technical transfer pricing guidance
• Ability to explain complex financial and economic concepts clearly to clients, tax authorities and internal stakeholders
• Ability to think creatively, solve complex problems and develop practical, commercially grounded recommendations
• Interest in identifying tax and business consulting opportunities and contributing to the growth of financial transactions transfer pricing services
• High motivation, initiative and interest in developing yourself and others, with the ability to manage, coach and retain a team of tax professionals

Thisposition ensures continuity and upholds our standards of excellence following the departure of a valued team member. The salary range for this position is $152,000 - $202,000.The posted salary rangerepresentsthe expected hiring range for PwC locations in major citycenters. Given our national recruiting approach, ranges may vary for positions in other locations. At PwC Canada, base salary isdeterminedby your skills, experience,qualificationsand work location.In addition to base salary, eligible employees may have opportunities toparticipatein variable incentive pay programs which are designed to reward individual and firm-wide achievements.We are committed to offering competitive compensation and adhering to all relevant pay transparency legislation. During the hiring process, our Talent Acquisition team will provide details about our comprehensive total rewards package.

Why you’ll love PwC

We’re inspiring and empowering our people to change the world. Powered by the latest technology, you’ll be a part of diverse teams helping public and private clients build trust and deliver sustained outcomes. This meaningful work, and our continuous development environment, will take your career to the next level. We reward your impact, and support your wellbeing, through a competitive compensation package, inclusive benefits and flexibility programs that will help you thrive in work and life. Learn more about our Application Process and Total Rewards Package at: https://jobs-ca.pwc.com/ca/en/life-at-pwc

PwC Canada acknowledges that we work and live across Turtle Island, on the land that is now known as Canada, which are the lands of the ancestral, treaty and unceded territories of the First Nations, Métis and Inuit Peoples. We recognize the systemic racism, colonialism and oppression that Indigenous Peoples have experienced and still go through, and we commit to allyship and solidarity.

We’re committed to providing accommodation throughout the application, interview, and employment process. If you require accommodation to be at your best, please let us know during the application process.

The use of artificial intelligence (AI) in recruiting is just getting started, so we know you have questions about how and why we use it. At certain points during our recruiting process, we rely on AI to improve your experience. This could be during resume review or curating personalized job recommendations, asking you clarifying questions via a chatbot or during our interview scheduling to improve your experience. Our use of AI helps ensure we combat bias by evaluating candidates equally and fairly, without seeing identity information, such as your name, or gender for example). AI also helps us better predict successful hires by reviewing all applicants for a role and the relationship between your skills, experience and likely success at PwC Canada. While AI supports parts of our recruitment process, final hiring decisions always involve human review. For more information about our use and protection of your data, please refer to our Privacy Policy (https://www.pwc.com/ca/en/privacy-policy.html).