Senior Transfer Pricing Documentation Specialist

🏗 We're Hiring: Senior Transfer Pricing Documentation Specialist

📍 Location: United Arab Emirates (Remote)

🕒 Employment Type: Full-Time

💼 Experience Level: Mid-Level to Senior

🌐 Work Arrangement: Fully Remote

About Us

We are a construction-focused organization committed to delivering complex projects through disciplined contract management, commercial excellence, financial transparency, and effective risk management. Our multidisciplinary teams collaborate across Project Management, Construction, Engineering, Procurement, Commercial, Legal, Finance, Human Resources, Design, Quality, HSE, Consultants, Contractors, Suppliers, Logistics, Administration, Information Technology, and Executive Leadership to support sustainable business operations and maintain strong financial governance.

We recognize the importance of accurate tax reporting, transparent intercompany transactions, and comprehensive documentation in managing cross-border business activities. Through robust transfer pricing policies, consistent documentation standards, and collaboration across finance, tax, legal, and operational teams, we aim to strengthen compliance, reduce tax-related risks, and support informed business decisions across our operations.

The Role

We are seeking an experienced Senior Transfer Pricing Documentation Specialist to manage and coordinate transfer pricing documentation, intercompany transaction analysis, related-party disclosures, and supporting tax compliance activities across the organization. The successful candidate will help ensure that related-party transactions are appropriately documented, commercially justified, and supported by evidence demonstrating compliance with applicable transfer pricing requirements.

The role will involve preparing and reviewing transfer pricing documentation, including master files, local files, intercompany transaction schedules, functional analyses, benchmarking studies, and related-party transaction records, as applicable. The specialist will collaborate with Finance, Tax, Legal, Procurement, Commercial, Project Management, and external tax advisers to assess intercompany arrangements, maintain audit-ready documentation, and support compliance with applicable United Arab Emirates corporate tax and transfer pricing requirements, as well as relevant international standards.

Key Responsibilities

• Lead the preparation, coordination, review, and maintenance of transfer pricing documentation for relevant entities and business operations.
• Prepare and maintain master files, local files, and other transfer pricing documentation where required by applicable regulations.
• Assess related-party transactions to determine documentation requirements, materiality, risk exposure, and compliance obligations.
• Identify, classify, and document related-party transactions involving goods, services, financing, guarantees, intellectual property, cost allocations, and other intercompany arrangements.
• Review intercompany transactions to ensure that the underlying commercial arrangements are accurately reflected in accounting records and tax documentation.
• Analyze intercompany agreements, service arrangements, financing agreements, management fee structures, cost-sharing arrangements, and other relevant contractual documentation.
• Conduct functional, asset, and risk (FAR) analyses to identify the functions performed, assets employed, and risks assumed by related parties.
• Document the commercial rationale, business purpose, pricing methodology, and economic substance of intercompany transactions.
• Assess whether related-party arrangements are consistent with the arm's length principle.
• Support the selection and application of appropriate transfer pricing methods based on transaction characteristics, available information, and applicable guidance.
• Review comparable uncontrolled transactions and other relevant market data to support transfer pricing analyses.
• Coordinate benchmarking studies for intercompany services, distribution activities, financing arrangements, construction-related services, procurement support, management fees, and other relevant transactions.
• Review comparable company searches, financial datasets, profitability indicators, and benchmark ranges prepared internally or by external advisers.
• Analyze relevant financial indicators, including operating margins, gross margins, markups on costs, return on assets, and other appropriate measures.
• Evaluate the suitability of selected comparables and document adjustments, assumptions, exclusions, and methodological limitations.
• Maintain clear records of benchmarking sources, search strategies, selection criteria, financial calculations, and conclusions.
• Review intercompany pricing policies to identify inconsistencies between contractual terms, actual business conduct, and reported financial results.
• Support the development, implementation, and periodic review of transfer pricing policies across relevant entities.
• Assess the consistency of transfer pricing policies with business models, operational responsibilities, contractual arrangements, and financial reporting practices.
• Coordinate with Finance and Tax teams to reconcile transfer pricing documentation with general ledger balances, trial balances, financial statements, and tax computations.
• Analyze intercompany revenue, expenses, receivables, payables, loans, interest charges, royalties, service fees, and cost recharges.
• Investigate discrepancies between intercompany agreements, invoices, accounting entries, and transfer pricing schedules.
• Support the accurate identification and disclosure of related-party transactions in financial statements and corporate tax filings.
• Assist in reviewing related-party transaction thresholds and other applicable criteria for transfer pricing documentation and disclosure obligations.
• Monitor relevant United Arab Emirates corporate tax requirements, transfer pricing regulations, Federal Tax Authority guidance, and applicable international standards.
• Maintain awareness of the OECD Transfer Pricing Guidelines and other relevant international developments affecting cross-border related-party transactions.
• Assess how changes in tax legislation, regulatory guidance, organizational structure, and transaction patterns affect documentation requirements.
• Coordinate the collection of financial, operational, contractual, and organizational information required for transfer pricing documentation.
• Work with business units to obtain accurate information about intercompany services, project activities, cost structures, resource allocation, and transaction flows.
• Collaborate with Procurement and Commercial teams to document related-party sourcing arrangements, subcontracting structures, procurement support services, and intercompany cost allocations.
• Support the analysis of related-party arrangements involving construction projects, engineering services, technical consultancy, equipment usage, project management, logistics, and shared operational resources.
• Review management service charges and cost allocations to assess whether the services were provided, provided a commercial benefit, and are appropriately supported.
• Help distinguish chargeable intercompany services from shareholder activities, duplicative services, and other costs requiring specific treatment under the applicable framework.
• Assess cost allocation methodologies, allocation keys, service descriptions, and supporting calculations for consistency and reasonableness.
• Support transfer pricing assessments for intercompany financing, including loans, cash pooling, interest rates, guarantees, and related financing fees where applicable.
• Coordinate with Treasury and Finance teams to obtain relevant financing agreements, repayment schedules, interest calculations, and supporting market information.
• Review the treatment of year-end transfer pricing adjustments and coordinate with accounting and tax teams on their documentation and reporting implications.
• Assist in evaluating proposed intercompany arrangements before implementation to identify documentation requirements and potential tax risks.
• Maintain a centralized repository of transfer pricing documentation, intercompany agreements, benchmarking studies, transaction schedules, and supporting evidence.
• Establish documentation standards, file naming conventions, review procedures, and version-control practices to support consistency and traceability.