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Manager, Transfer Pricing

Job Number:  9161
Group:  Magna Corporate
Division:  Magna Servicios de Mexico
Job Type:  Permanent/Regular

San Pedro Garza Garcia, MX

Group Description


At Magna, we create technology that disrupts the industry and solves big problems for consumers, our customers, and the world around us. We’re the only mobility technology company and supplier with complete expertise across the entire vehicle.

We are committed to quality and continuous improvement because our products impact millions of people every day. But we’re more than what we make. We are a group of entrepreneurial-minded people whose collective expertise gives us a competitive advantage. World Class Manufacturing is a journey and it’s our talented people who lead us on this journey.


Role Summary

A Transfer Pricing Manager performs the planning, review, execution and supervision of the implementation of intercompany transactions within the Multinational Group in order to comply with the Arm’s Length principle stated by the OECD Guildelines. Its main role is to make sure that the considerations for any type of intercompany transactions comply with local and cross-border requirements appointed by different Tax Authorities and subsequently preparing the support Transfer Pricing documentation.

Key Responsibilities
  1. Plan and execute transfer pricing policies for any type of intercompany transactions rendered between related parties.
  2. Review and confirm on the correct application of transfer pricing policies received/provided to/from divisions on a periodic basis, related to royalties, intercompany services, tangible products, other services as per OECD Guidance.
  3. To review and reconcile differences berween intercompany amounts shown by local divisions and their domestic or foreign related parties.
  4. Ensure transfer pricing analyses for certain foreign intercompany transactions maintain consistency, and at the same time, that they show compliance with the local rules of each jurisdiction and as per OECD Guidance.
  5. Involved in the preparation of contemporaneous Transfer Pricing documentation (Local and Master Files). Request information from local and foreign divisions, review, analyze and, later on, utilize that information for preparation of the documentation, as well as reviewing and making suggestions and changes to the draft documentation to finalize these items. Organize and maintain electronic versions of these documents and their working papers for future reference and audit purposes.
  6. Involved in preparing and assisting to comply with Mexican tax information returns such Annex 9 DIM, DISIF Apartados 15 and 15 DAIPR which includes the electronic presentation of the Local and Master Files.
  7. Analyze and disseminate intercompany transaction related information required for local and foreign tax authority audits. For audit defense compiling and reviewing relevant information, preparing audit responses and participating in meetings with various authorities.
  8. Supporting divisions by solving doubts or concerns regarding intercompany structure and transfer price issues during their day-to-day operations. To ensure that divisions are well-informed and updated on any type of transfer pricing policy or statutory changes in the Mexican taxation law.
  9. To assist other Global Transfer Pricing group on any type of information requirements from local divisions. Analyze and review information collected from Mexocan divisions before these are utilized for Transfer Pricing documentation purposes.
  10. To perform site visits and interviews in order to understand and document the divisional functions and risk analysis as well as keep divisions management aware regarding relevant tax and transfer pricing topics. Review and update Transfer Pricing documentation based on annual functional analysis interviews conducted during site visits. Also perform similar functional analysis interviews via conference calls with relevant foreign related parties.
Key Qualifications/Requirements
  1. Bachelor´s degree and above in the areas of Economics, Accounting or Finance.
  2. Language proficiency both in oral and written English, preferable proven by TOEFL, TOEIC, Cambridge or IELTS tests.
  3. At least a 5-year+experience on the Transfer Pricing area, whether on the private sector (in-house, consulting) or the public sector (Ministry of Finance or SAT).
  4. Participation and experience in the preparation of Transfer Pricing documentation, as well as tax planning and tax audits.
Additional Information
  1. Technical skills and specific Transfer Pricing knowledge
  2. Organized at work.
  3. Productivity and quantity of work performed.
  4. Time management and planning for specific deadlines.
  5. Effective communications with its immediate supervisor as well  as with other members of the tax team.

03--Finance F--Permanent/Regular 

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