Transfer Pricing Manager

Circle 🌐💸💡

Salary range

$130,000–$170,000/year

Benefits

Job Description

Responsible for the end-to-end operational transfer pricing (TP) lifecycle—policy design, operationalization and documentation—so our inter-company pricing is compliant, defensible, and aligned with business reality. Involved in TP planning and controversy as required, partnering closely with Finance, Accounting, Treasury, Legal, and the business to keep policies current as we grow and as rules evolve. Embed pricing in systems and processes (e.g. Oracle, AI tools); ensure accurate charge-outs, cost allocation bases, and inter-company agreements (ICAs). Responsible for monthly operational TP including set-up, calculations, testing, billing, journals, experience with Oracle ERP will be key. Own Master File, Local Files, and Country-by-Country Reporting (CbCR); ensure on-time, audit-ready packages and a clean transaction register. Coordinate local advisor work, translations, and statutory needs. Assist in design pricing for new flows, restructurings, and business launches; build robust models and benchmarking using appropriate methods (CUP, TNMM, CPM, Profit Split). Maintain and evolve global TP policies across all group transactions. Translate regulatory change into practical policy and controls.

About Circle

Circle is a financial technology company at the epicenter of the emerging internet of money, where value can finally travel like other digital data.

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