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

Tax Manager: 104011

Base Location: Bristol or Cardiff plus network of 20 offices nationally: www.kpmgcareers.co.uk/experienced-professional/#LeBlender.OfficeLocations

Why Join KPMG as a Tax Manager within our Corporate Tax Compliance & Advisory Team based in the South region

You’ll join a high performing team advising on a broad range of clients from early-stage start-ups, successful privately owned businesses, and some of the world’s largest and most complex organisations.

You will be responsible for managing the tax relationship across a diverse portfolio of clients which will provide you a broad range of technical experience. You will take on a variety of projects covering international tax, treasury tax, group restructuring, tax governance, group reporting and domestic tax advisory and compliance.

The role will suit a Manager wanting to drive their tax career. 

The team is diverse and collaborative, with individuals based across Bristol, Reading, Cardiff & Southampton. We embraced hybrid and flexible working long before it became the norm! Our team has a mix of backgrounds and whatever your background we will give you the support, encouragement, and training to thrive at KPMG.

What will you be doing?

Working as a key member of the team to provide corporate tax advice to a broad range of clients helping them to achiev

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.

This exciting role is within our South Corporate Tax Advisory & Compliance team, based in our South Central or South West offices.

Our clients include UK headquartered businesses and inbound groups across a range of sectors. 

Our work in the tax advisory space includes supporting clients with business and fiscal change. This can include advising on new jurisdiction entry, the development of new business areas, business reorganisations, tax authority enquiries, pre/post transaction reorganisations, refinancing, cash repatriation, interest deductibility and the impact global fiscal change (e.g. BEPS Pillar 2).

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

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.