KPMG’s Fixed Asset Tax Services Team (capital allowances) is made up of tax advisers, accountants, chartered surveyors and ex-HMRC inspectors who deliver expert advice to a broad range of clients across almost every industry sector. As one of the largest teams in the industry, our continued investment and desire to grow means that we seek a capital allowances specialist in Scotland.

Our team works with clients ranging from owner-managed businesses to large multinational organisations. We are seeking a Senior Manager to join our Scotland team who has a background in capital allowances, tax or accounting. The work is varied and will be across a number of sectors.

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

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Where Tax excellence meets global impact.

London is home to KPMG’s largest Tax & Law community — a place where technical depth, international reach and advanced technology converge to help organisations navigate a rapidly changing world. From global tax reform to ESG reporting, from digital transformation to cross‑border advisory, the work you’ll do here helps businesses operate responsibly, transparently and with confidence.

If you want to influence the decisions that shape industries, drive trust and support sustainable growth, this is where you can #MakeTheDifference.

Deal Advisory Tax is a dynamic and successful area of KPMG’s Tax & Legal business.  We have an inclusive and collaborative leadership strategy and are making bold changes to our culture and how we work.  A constantly changing and high-profile field, we work in a fast-paced, challenging and rewarding environment, and can offer a broad range of quality career paths to ambitious people.

Deal Advisory Tax

Infrastructure – Assistant Manager

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.

Deal Advisory Tax is a dynamic and successful area of KPMG’s Tax & Legal business.  We have an inclusive and collaborative leadership strategy and are making bold changes to our culture and how we work.  A constantly changing and high-profile field, we work in a fast-paced, challenging and rewarding environment, and can offer a broad range of quality career paths to ambitious people.

The Role

Deal Advisory Tax provides market leading services to both Financial and Corporate investors.  Whilst we have teams focused on clients in our three performance groups of Financial Services, Corporates and National Markets, we are a national and connected team, working and learning with each other.

• Financial Services: We work with private equity, infrastructure, and real estate funds as well as institutional investors such as sovereign wealth funds and pension funds.  Our clients have UK, European and Global investment strategies.
• Corporates: We work alongside some of the most forward-thinking FTSE 100 and 250 businesses, supporting them with strategic acquisitions, carve outs, de-mergers, disposals, and joint ventures both in the UK and cross-border.
• National Markets: We work across the UK with mid-market corporates and PE funds, looking to invest across key UK sectors to grow our local economies.

The Deal Advisory Tax team provides advisory services across the whole deal spectrum including buy-side due diligence and structuring, sell-side vendor assist and vendor due diligence, refinancing, and listing support. Deal sizes can be anywhere from £10m to +£10bn – we work with a variety of clients and on a variety of deals.

We help our clients understand historical tax issues and structure transactions, with a continuous focus on maximising value throughout the investment cycle. Working collaboratively across the KPMG network, our work often involves advice on multiple countries, taxes, and work streams.

Key Responsibilities

• Work closely with Partners and/or Directors on complex transactions to deliver exceptional advice and service
• Support in the pursuit of new opportunities, working on proposals and joining pitches.
• Develop and maintain client relationships alongside Deal Advisory.
• Be a key KPMG point of contact for clients, legal advisers, and other KPMG teams to facilitate effective delivery.
• Coach and develop colleagues, collaborate with peers, and be constantly learning.
• Prepare/ oversee detailed technical advice covering a range of UK and international tax issues.
• Perform/ oversee detailed analysis of tax related documents/ data, highlighting key issues and articulating the commercial impact of these to the client.
• Collaborate with other UK and overseas tax specialists, critically analysing and challenging their input.
• Demonstrate up-to-date tax technical knowledge in respect of key UK and OECD developments.
• Understand financial models from a tax perspective.
• Input on Deal Advisory Tax thought leadership.

The Person

D Grade

1. • Qualified CTA or ACA/ CA or equivalent
   • Enthusiastic and a keen interest in working on transactions
   • Good interpersonal skills
   • Good oral and