Transfer Pricing/Value Chain Manager

Transfer Pricing Manager, Value Chain Alignment

You've spent years building real transfer pricing expertise. You understand OECD principles, you can analyse value chains with confidence, and you know how to turn a complex cross-border structure into a clear, practical recommendation. The technical capability is there. The question is whether your current role is actually using it.

If you're spending more time on compliance and documentation than on the kind of structural, strategic work that first drew you to this field, if the clients you're serving have interesting problems, but the mandates never quite let you get to the heart of them, this role was written for you.

What this role is really about

This is an advisory role, genuinely. You'll be working alongside the Partner leading value chain alignment across South-East Asia and APAC, advising multinational clients on the tax and transfer pricing dimensions of how they actually run their businesses. Business model redesign. Operating model change. Supply chain restructuring. The moments when a company's legal and tax structure either holds up under scrutiny or quietly starts to diverge from commercial reality.

That divergence is where your work begins. You'll help clients see where the gaps are, design structures that are robust and commercially grounded, and think through the controversy implications before they become someone else's problem to fix.

The work itself

Day to day, you'll be advising on transfer pricing and tax issues at the point where they intersect with real business decisions. Principal structures, distribution model changes, regional hub arrangements, DEMPE analysis, intangible ownership, the full range of issues that arise when a multinational group's operating model evolves and the tax architecture needs to keep pace.

You'll manage engagements from planning through to delivery, supervise and develop junior members of the team, and work across the broader Tax practice, including transfer pricing, international tax, indirect tax, and where relevant, other service lines. The deliverables you produce will reach CFOs, General Counsel, and regional tax leads. They need to be clear, technically sound, and genuinely useful. That standard is the baseline here, not the aspiration.

You'll also be a real part of building this practice. That means contributing to proposals, developing thought leadership, identifying where a client conversation on one issue connects to a broader business challenge, and helping shape the team's value chain alignment offering as it grows across the region.

What you'll bring

We're looking for someone with five to eight or more years of experience in transfer pricing, international tax, or closely related advisory work, ideally in professional services or a complex in-house environment where the work was substantive and the stakes were real.

You should have a solid grounding in OECD transfer pricing principles and genuine experience applying them in practice, not just in documentation, but in structuring advice and navigating difficult client situations. Experience with business restructurings, operating model analysis, or value chain projects will stand out. Familiarity with the APAC region, and the particular complexities of cross-border structures across South-East Asia, is a real advantage.

Beyond the technical, we're looking for someone who can think commercially, communicate clearly at senior levels, manage competing priorities without losing quality, and take genuine ownership of their work. A degree in Accounting, Law, Economics, Finance, or a related discipline is expected. More important is the judgement and intellectual honesty to tell clients what they need to hear, not just what they want.

The honest version

This role will ask a lot of you. The clients are sophisticated, the issues are complex, and the expectation is that you'll manage your work with a level of autonomy that not every environment has prepared people for. If that's a concern, it's worth being honest about it.

But if you're at a point in your career where you want to work on the kind of mandates that require real intellectual depth, where your expertise shapes the advice rather than just supports it, and where the region you're working in is one of the most commercially dynamic in the world, then this is a serious opportunity worth taking seriously.

If this sounds like where you should be, we'd like to hear from you. Please contact Aaron Leslie at: al@tpi-search.com