Transfer Pricing

Grade: C

Job Title: Transfer Pricing Manager specialising in Transfer Pricing Audit

Recognised in the marketplace for our technical excellence, Transfer Pricing at KPMG is an integral part of the firm’s global community. Our firm is also renowned for its technical excellence in Audit, delivering high‑quality, rigorous audit work underpinned by strong analytical capability and professional scepticism. KPMG’s specialist Transfer Pricing Audit team sits within the firm’s national transfer pricing team and audits the transfer pricing arrangements of a range of businesses to identify transfer pricing risks.

Our team works on a broad range of audits from FTSE100 Group reporting engagements to UK statutory audits.

The KPMG specialist audit team have high levels of technical expertise and team members below partner and director work closely with the partners and directors in the team. There is extensive on the job coaching as well as more regular technical training sessions. The nature of the work provides an ideal environment for team members to rapidly increase their technical skills seeing a wide variety of audits. 

The team is a virtual team and there is the ability to work from any location.

The Responsibilities/Job Description

This role involves working on a range of audits to test whether the tax on the transfer pricing arrangements materially complies with the arm’s length principle as set out in the UK Transfer Pricing legislation.

Day to day, the work involves:

• Managing various transfer pricing audits and leading the day-to-day transfer pricing audit processes
• Coordinating with KPMG's Audit and Tax Audit teams on a range of audits
• Acting as the main point of contact for audit entity management teams
• Speaking to Audit Entities to obtain the facts
• Coaching and developing junior team members which will also include delivering training sessions and providing on-the-job coaching on a regular basis
• Ensuring timely reporting to senior management
• Actively contributing to sharing transfer pricing audit knowledge to the transfer pricing advisory team

The Person

We are looking for candidates with the following skills/experience:

• Either a CTA, CA, ACA, ACCA or attained a Bachelors or Masters degree in economics, finance, law, accounting or equivalent qualification
• Transfer pricing experience: preferably including experience of transfer pricing audits, policy setting, tax authority enquiries/Advance Pricing Agreements, operational transfer pricing, financing transfer pricing, project management and managing junior team members; or significant audit experience  
• Sound judgement and an enquiring mind, including the ability to objectively assess and challenge management’s assumptions and exercise professional scepticism
• Strong analytical skills and attention to detail
• High level of drive and enthusiasm with a positive attitude
• Keen ability and willingness to keep up to date technically and develop the technical ability of the team below you
• Ability to work autonomously and to take initiative as appropriate
• Highly organised with excellent communication and project management skills

At KPMG, our values define who we are and the way we do business. As a leading professional services firm, we know that our strength and capability come from our people: their different perspectives, experiences and backgrounds. From our inclusive leadership strategy to our diversity and inclusion targets – we are making bold changes to who we are and what we do. Be part of it.

Overview

KPMG is part of a global network of firms that offers Audit, Tax, Pensions & Legal, Consulting, Deal Advisory and Technology services. Through the talent of over 16,000 colleagues, we bring our creativity and insight to our clients’ most critical challenges. As a firm we help our clients navigate their biggest issues and opportunities. We aim to be universally recognised as a great place for great people to do their best work – a firm known for our collaborative and inclusive culture. And we will take pride in driving lasting, positive change in society. 

With offices across the UK, we work with everyone from small start-ups and individuals to major multinationals, in virtually every industry imaginable. Our work is often complex, yet our vision is simple: to be the clear choice for our clients, for our people and for the communities we work in.

We work as a hybrid team where we get together in the office or at client sites at least three times a week to collaborate and learn together, with flexibility over how you spend the rest of your time. 

The role

An exciting opportunity for a motivated individual to join our Scotland Corporate Tax Advisory & Compliance team as a Manager, based in our Edinburgh, Glasgow or Aberdeen office.  Our client base and the services we provide are varied, so you've got a great opportunity to help shape how you spend your time.  Key aspects of the role will involve:

• Being responsible for delivery of the corporation tax compliance work on a portfolio of clients and working with Senior Managers, Directors and Partners on our larger client accounts
• Being involved in tax advisory projects including advice closely linked to the compliance work such as on controlled foreign companies and the corporate interest restriction, as well as assisting on ad hoc advisory projects
• Being responsible for the delivery of tax accounting work and working with Senior Managers and Directors on tax reporting work
• Ensuring our clients are kept up to date with emerging corporate and wider tax developments impacting their business
• Supervising the work of junior members of staff and providing coaching to support their development
• Being responsible for and reporting to Directors and Partners on client account management, including complying with appropriate quality and risk management procedures and financial management
• Support the leadership with business development opportunities

The role would involve a mixture of tax compliance, reporting and advisory work and there would be flexibility around the weighting of time to these different components of the role based on your experience and areas of interest.

The person

• Qualified CTA or ACA / CA or equivalent

• UK corporation tax experience
• Sustains a high level of energy, shows enthusiasm and a positive attitude that translates across the team
• Displays an inclusive, collaborative approach and operates in a respectful manner with colleagues, clients, and the wider community
• Brings insight and effectively applies knowledge to business and client problems
• Communicates with impact, in a way that is open, honest, consistent and clear

• Strong oral and written communication skills
• Strong analytical skills, curious

Core Responsibilities of the FDE Team Include:

•              Developing and managing bespoke AI solutions tailored to clients’ specific needs, resulting in actionable outcomes and accelerated decision-making.

•              Engage proactively to support member firm client opportunities, quickly pinpointing key clienty challenges and uncovering opportunities for value creation through in-depth analysis and collaborative workshops

•              Enabling teams through cutting-edge prototyping tools and methodologies to enhance delivery efficiency and impact.

•              Partnering with global teams and networks to implement the latest emerging technologies and innovations.

•              Reporting and tracking key performance indicators to measure the success and scalability of FDE initiatives globally.

•              Creating supportive, data-driven environments for teams to innovate continuously and achieve sustained client transformation.

A key focus for KPMG’s GCT team is to help multinational groups and financial services clients manage their global tax compliance, reporting and statutory accounting obligations, through outsourcing, co-sourcing, transformation and technology. More information about our team is at the end of this job description.

The Tax Technical team is a critical enabler to all tax activities within GCT and provides expertise into KPMG’s complex tax audits.  Audit quality is of paramount importance and to do this efficiently, we maintain a dedicated and enthusiastic team of tax specialists.  We are also the engine room of the tax reporting, compliance, governance and low-level advisory work undertaken by the wider GCT team – servicing large domestic compliance clients as well as our Global Compliance clients.

Legal Advisor (Patent Lawyer)

Based: London or any key site - including Manchester, Glasgow, Edinburgh, Leeds and Bristol: 

Role summary

KPMG is now a digital business, and as a result, technology enables everything it does and requires KPMG to continue to transform with technology in support of its Growth and Trust agenda. This role, which is focused on the product and innovation aspects of Intellectual Property (IP), Technology and Data, is a part of the International Office of the General Counsel (IOGC).  It focuses on providing legal advice and support from IOGC on the development, protection, enforcement, acquisition and licensing of technology, software and data, particularly risks, protections and opportunities related to the patent aspects of KPMG’s IP, technology and data strategy.

Although this role is primarily focused on product and innovation, this role may also involve providing support to other IOGC lawyers on strategic initiatives and commercial technology transactions, particularly where the licensed technology is protected by patents, is not patent protected but is in a highly patented field, and/or leverages artificial intelligence and blockchain.

The person in this role will execute their responsibilities under the overall supervision of, and working collaboratively with, the most senior patent lawyer with respect to IP, Technology and Data and other senior lawyers focused on IP and technology law. This role requires a person to provide meaningful value-add to business and technology development teams by supporting product and innovation that contributes to over $17 billion in annual revenue, helping to analyse KPMGI’s intellectual property (IP) and technology assets, and advising on patent protection and IP enforcement, all while supporting IOGC’s senior leadership team in managing, mitigating and preventing legal and reputational risk.

The role is an excellent opportunity for a junior lawyer who has focused on patent work (prosecution, litigation, licensing, freedom to operate) to apply their skills to a rapidly growing international patent pipeline focused on emerging technologies and to expand their IP skillsets beyond patent law in a rapidly growing digital business.