Circle · 2 months ago
Transfer Pricing Manager
Circle is a financial technology company focused on the emerging internet of money, enabling global transactions through innovative blockchain solutions. The Transfer Pricing Manager will oversee the operational transfer pricing lifecycle, ensuring compliance and alignment with business realities while collaborating with various departments to maintain effective pricing policies.
BankingBlockchainCryptocurrencyFinancial Services
Responsibilities
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
Build repeatable data pipelines for TP; manage and drive further automation and analytics (Oracle, AI tools)
Measure and improve cycle times, quality, and control effectiveness
Be control owner for TP operational controls: walkthroughs, test scripts, evidence, and remediation
Produce support packs that feed Master/Local Files and CbCR (Table 1 mapping consistent with ledgers)
Coordinate with local advisors for statutory nuances; keep a clean PBC trail for audits
Assist in the 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
Qualification
Required
8–12+ years TP experience (Big Four/consulting and/or in-house); exposure to multi-jurisdiction groups
Degree in Tax/Accounting/Economics/Finance; advanced degree or tax qualification preferred
Deep knowledge of OECD Guidelines, BEPS (incl. Actions 8–10 & 13) and key local rules (e.g., US §482/EU frameworks)
Hands-on with benchmarking, financial modeling, and documentation for services, and IP/DEMPE analyses
Comfortable operationalizing policy in ERP environments (Oracle), and partnering with Accounting on close/true-ups
Excellent stakeholder management and clear written/oral communication; able to explain TP to non-tax leaders
Project management chops: plan, prioritize, and deliver across multiple countries and deadlines
Preferred
Experience with Oracle Fusion and PCM a bonus
Experience/familiarity with Slack, Apple MacOS and GSuite
Company
Circle
Circle helps businesses and developers utilize stablecoins for payments and online commerce.
H1B Sponsorship
Circle has a track record of offering H1B sponsorships. Please note that this does not
guarantee sponsorship for this specific role. Below presents additional info for your
reference. (Data Powered by US Department of Labor)
Distribution of Different Job Fields Receiving Sponsorship
Represents job field similar to this job
Trends of Total Sponsorships
2025 (32)
2024 (41)
2023 (43)
2022 (25)
2021 (4)
2020 (2)
Funding
Current Stage
Public CompanyTotal Funding
$2.44BKey Investors
ARK Investment ManagementCoinbaseAlameda Research
2025-11-19Post Ipo Secondary· $17.7M
2025-08-14Post Ipo Secondary· $1.04B
2025-08-14Post Ipo Equity· $260M
Recent News
Crowdfund Insider
2026-01-12
Company data provided by crunchbase