Transfer Pricing Senior Manager
Our client is recognised as one of Canada’s leading law firms, representing a diverse client base including many FT Global 500 companies.
The firm has acquired top-tier expertise in tax dispute resolution and litigation, transfer pricing, international tax, tax incentives (SR&ED, e-business and resources credits), tax planning and indirect taxes primarily for multinational enterprises.
The firm is also recognised as one of Canada’s leading law firms in transfer pricing, both at the advisory and dispute resolution level. Assisting multinational enterprises in all facets of their Canadian transfer pricing needs, from advising on transactions, recommending process improvements for documentation, and analysing valuations or basis of provisions for Fin 48 and other reporting purposes, to defending positions at any level from audit, through the administrative appeals level and competent authority proceedings. The firm's lawyers regularly assist the firm’s clients in managing transfer pricing risks associated with ongoing operations, business restructurings (e.g., mergers, acquisitions and divestitures) and special transactions (e.g., migration or licensing of intellectual and other property).
There is a new and exciting opportunity for a dynamic Transfer Pricing Laywer with 5-8 yrs PQE to join the firm and have immediate involvement in the following:
Providing assistance in the context of tax audits, appeals litigation and recourses before Canadian and foreign administrations (APAs/MAP).
- Developing audit defence strategies, analysing options for dispute resolution.
- Working with all TP methodologies.
- Bringing value in financial and economic analysis.
- Reviewing valuations in the context of business reorganizations, impairment testing or tax litigation.
- Designing transfer pricing policies and analysing tax treaties. 6. Attribution of profits to permanent establishments.
- Transfer Pricing specialist with 5-8 years PQE, ideally legally qualified with professional experience acquired in Big 4, or a law firm environment achieving significant depth and breadth in TP expertise (e.g., trained by and with economists; large files, broad experience, such as is common in Global Accounting Firms).
- Excellent experience in financial analysis.
- Excellent interpersonal skills, a team worker.
- Perfect command of English. Knowledge of French is an asset.
- The position is based in Montréal (Québec) (a remote position may be feasible).