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This position reports to:
Global Transfer Pricing Practice Lead
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We are seeking an experienced Transfer Pricing Manager for Central/HQ Services to own and further develop the group’s transfer pricing framework for central and headquarters services. The role is responsible for service fee models, documentation, governance, and advisory support across businesses and functions, ensuring compliance, consistency, and value alignment with OECD transfer pricing guidelines and country regulations.
This role sits at the intersection of tax, finance, and business, and requires deep technical transfer pricing knowledge combined with pragmatic stakeholder management.
“We’re serious about transfer pricing compliance - but we don’t believe it has to be boring.”
Your responsibilities:
Service Fee Design & Documentation
* Design, maintain, and enhance service fee frameworks, including allocation keys, mark-up policies.
* Review intra-group service agreement templates, and own core documentation for central license, service and finance transactions.
* Ensure alignment with OECD Transfer Pricing Guidelines, local regulations, and internal policies.
Cost Reviews & Charge-Outs
* Oversee cost reviews and HQ charge-outs.
* Ensure sound practices, audit readiness, and transparency of cost bases and allocation methodologies.
Advisory & Business Partnering
* Act as the transfer pricing advisory lead for Central/HQ services.
* Support business, finance, and tax stakeholders on new services, reorganizations, and changes in service models.
* Provide guidance on business-specific service charge-outs and bespoke arrangements.
Audits, Controls & Governance
* Support in related tax and statutory audits in all countries where ABB operates.
* Contribute to internal controls, transfer pricing governance, compliance processes and risk assessments.
Transfer Pricing Team
* Support ABB’s global transfer pricing and tax team in various transfer pricing related matters.
* Closely collaborate with other transfer pricing team members.
Your background:
* At least 5-8 years of experience in transfer pricing, either as a consultant or in-house.
* In-depth understanding of OECD Transfer Pricing Guidelines and service fee models.
* Experience working with shared service center or HQ cost allocations.
* Master’s or bachelor’s degree in accounting, finance, legal or tax.
* Ability to work in an environment with shifting priorities and evolving business needs.
* Good analytical skills.
* Effective stakeholder management and communication skills.
* Fluent in English; additional languages are an advantage.
* Appreciates and works effectively within diverse cultural environments.
What's in it for you:
* Global, multi-cultural team.
* An opportunity that offers notable visibility on a global scale.
* Exposure to complex, cross-border service structures in an evolving environment.
* Collaboration with senior tax, finance, and business stakeholders.
* Training and career development opportunities.
Building a cleaner, smarter future takes all kinds of minds: the curious, the courageous, and the creative. That's why we welcome people from all backgrounds and experiences.
Ready to make an impact?
Apply today or visit https://www.abb.com to learn more about the impact of our solutions across the globe.