Line of Service

Tax

Industry/Sector

Not Applicable

Specialism

Transfer Pricing

Management Level

Director

Job Description & Summary

A career within our Transfer Pricing & Customs practice will provide you with the opportunity to help multinational clients navigate complex cross-border tax, trade and financing matters. Our team advises clients on transfer pricing, customs valuation, trade compliance and international tax planning, helping them achieve compliant, commercially sound outcomes aligned with evolving global regulatory expectations.

In this role, you will focus on financial transactions transfer pricing, including interest rate analyses, debt capacity, cash pooling, guarantees, hedging, providing services related to documentation, planning and dispute resolution matters. You will primarily support complex intercompany financing projects and collaborate closely with tax, treasury, valuation and legal stakeholders.

Driven by curiosity, you are a reliable, contributing member of a team. In our fast-paced environment, you are expected to adapt to working with a variety of clients and team members, each presenting varying challenges and scopes. Every experience is an opportunity to learn and grow. You are expected to take ownership and consistently deliver quality work that drives value for our clients and success as a team. As you navigate through the Firm, you build a brand for yourself, opening doors to more opportunities.

The opportunity

As a Transfer Pricing Director focused on Financial Transactions, you’ll work as part of a team of problem solvers, helping clients address complex intercompany financing issues while delivering high-quality client service and practical, supportable recommendations. Responsibilities include but are not limited to:

Lead and manage financial transactions transfer pricing projects, including intercompany loan pricing, debt capacity analyses, guarantee fee analyses, cash pooling arrangements and related documentation

Oversee multiple client engagements, ensuring quality and timely delivery

Develop robust economic analyses that consider credit risk, capital markets data, borrower and lender perspectives, and the commercial terms of related-party financing arrangements

Prepare and review technical memoranda, transfer pricing reports and client deliverables that clearly explain methodologies, assumptions, conclusions and supporting evidence

Advise clients on transfer pricing planning, controversy, and audit defence matters involving intercompany financing transactions

Build and grow client relationships by understanding clients’ businesses, treasury policies, financing structures and broader tax objectives

Use financial data, market evidence and technology-enabled tools to develop efficient,



defensible and insightful analyses

Explore and embrace emerging technologies, including artificial intelligence, and guide the team in incorporating these tools to enhance the quality and efficiency of client service delivery

Collaborate with PwC tax, valuation and international network teams to deliver integrated advice on complex cross-border financing issues

Guide, coach and develop team members by providing explicit direction, technical guidance and timely feedback on financial transactions transfer pricing work

Contribute to business development by identifying client needs, supporting proposals and helping market financial transactions transfer pricing services to existing and prospective clients

Uphold the firm’s code of ethics and business conduct

What you’ll bring

Demonstrated experience in transfer pricing at the Director level, with significant experience advising on financial transactions and intercompany financing arrangements:

Strong knowledge of financial transactions transfer pricing concepts, including arm’s length interest rate setting, credit ratings, credit risk, debt capacity, guarantees, cash pooling and capital structure considerations

The CFA or CPA designation is a strong asset

MBA, MA or advanced degree in Economics, Tax, Finance or Business Administration, or an equivalent combination of education and professional experience

Strong research, writing and quantitative analytical skills, with comfort working with detailed financial analysis, capital markets data and technical transfer pricing guidance

Ability to explain complex financial and economic concepts clearly to clients, tax authorities and internal stakeholders

Ability to think creatively, solve complex problems and develop practical, commercially grounded recommendations

Interest in identifying tax and business consulting opportunities and contributing to the growth of financial transactions transfer pricing services

High motivation, initiative and interest in developing yourself and others, with the ability to manage, coach and retain a team of tax professionals

Thisposition ensures continuity and upholds our standards of excellence following the departure of a valued team member.

The salary range for this position is $152,000 - $202,000.The posted salary rangerepresentsthe expected hiring range for PwC locations in major citycenters. Given our national recruiting approach,



ranges may vary for positions in other locations. At PwC Canada, base salary isdeterminedby your skills, experience,qualificationsand work location.In addition to base salary, eligible employees may have opportunities toparticipatein variable incentive pay programs which are designed to reward individual and firm-wide achievements.We are committed to offering competitive compensation and adhering to all relevant pay transparency legislation. During the hiring process, our Talent Acquisition team will provide details about our comprehensive total rewards package.

Why you’ll love PwC

We’re inspiring and empowering our people to change the world. Powered by the latest technology, you’ll be a part of diverse teams helping public and private clients build trust and deliver sustained outcomes. This meaningful work, and our continuous development environment, will take your career to the next level. We reward your impact, and support your wellbeing, through a competitive compensation package, inclusive benefits and flexibility programs that will help you thrive in work and life. Learn more about our Application Process and Total Rewards Package at: https://jobs-ca.pwc.com/ca/en/life-at-pwc

PwC Canada acknowledges that we work and live across Turtle Island, on the land that is now known as Canada, which are the lands of the ancestral, treaty and unceded territories of the First Nations, Métis and Inuit Peoples. We recognize the systemic racism, colonialism and oppression that Indigenous Peoples have experienced and still go through, and we commit to allyship and solidarity.

Education (if blank, degree and/or field of study not specified)

Degrees/Field of Study required:

Degrees/Field of Study preferred:

Certifications (if blank, certifications not specified)

Required Skills

Optional Skills

Accepting Feedback, Accepting Feedback, Active Listening, Analytical Thinking, Base Erosion and Profit Shifting (BEPS), Business Tax, Coaching and Feedback, Communication, Consolidated Tax Returns, Corporate Structuring, Creativity, Economic Translation, Embracing Change, Emotional Regulation, Empathy, Financial Modeling, Financial Statement Analysis, Financial Structuring, Inclusion, Influence, Innovation, Intellectual Curiosity, International Taxation, Learning Agility, Legal Document Review {+ 23 more}

Desired Languages (If blank, desired languages not specified)

Travel Requirements

Not Specified

Available for Work Visa Sponsorship?

No

Government Clearance Required?

No

Job Posting End Date

We’re committed to providing accommodation throughout the application, interview, and employment process. If you require accommodation to be at your best, please let us know during the application process.

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📌 Transfer Pricing - Financial Transactions, Director (Ontario)
🏢 PwC
📍 Ontario