Senior Manager, Transfer Pricing Controversy

Job Description

Eaton’s Tax Team is currently seeking a Senior Manager, Transfer Pricing Controversy to join our team! This position is based at Eaton Center in Beachwood, OH.

The Senior Manager, Transfer Pricing Controversy assists in insourcing and displacing substantial high-cost professional services from major outside law firms on tax planning and transfer pricing projects, tax controversy matters, and tax litigation in the Americas and EMEA regions.  This position reports to the Tax Counsel & Director of Transfer Pricing Controversy.


The Senior Manager, Transfer Pricing Controversy works within the global Transfer Pricing Strategy Team and manages the Americas and EMEA regional Transfer Pricing Controversy teams. This individual will play a major role in reducing outside legal fees related to the evaluation of local country rules and tax policy shifts focused on the taxation of intercompany transactions, which are expected to exponentially increase tax controversy worldwide.  This individual will also be responsible for reviewing all major transfer pricing transaction flows from a tax controversy perspective.


Making what matters work at Eaton takes the passion of every employee around the world. We create an environment where creativity, invention and discovery become reality, each and every day. It’s where bold, bright professionals like you can reach your full potential—and where you can help us reach ours. In this role you will:

  • Assist with the legal review of all targeted areas of transfer pricing audits in the Americas and EMEA.
  • Assist with legal support for Tax Appeals in the Americas and EMEA, including evaluation of hazards of litigation and negotiation of settlements, focusing primarily on transfer pricing issues.
  • Assist with the legal support for all Eaton transfer pricing controversies and litigation in the Americas and EMEA, including proactive management of the evidentiary aspects of the case, risk evaluation, and participation in field visits by tax authorities.
  • Assist with the legal review of all major transfer pricing planning & implementation strategies affecting the Americas and EMEA, including identification and evaluation of potential trial experts at the beginning of the project and review of documentation supporting execution and technical positions.
  • Assist with the legal review of tax accounting for uncertain tax positions & evaluations of tax reserves, including input into public filing disclosures
  • Evaluate transfer pricing risk worldwide and manage the evidentiary aspects of transfer pricing documentation, including master file, country-by-country report and local file reports
  • Develop and manage the transfer pricing controversy teams in the Americas and EMEA, and support the development of the transfer pricing controversy team in APAC.
  • Ensure alignment of transfer pricing positions globally in order to successfully defend and provide consistency in technical analysis/position.

When we embrace the different ideas, perspectives and backgrounds that make each of us unique, we — as individuals and as a company — are stronger.


We are committed to ensuring equal employment opportunities for all job applicants and employees. Employment decisions are based upon job-related reasons regardless of an applicant's race, color, religion, sex, sexual orientation, gender identity, age, national origin, disability, marital status, genetic information, protected veteran status, or any other status protected by law.


Basic Qualifications:

  • Bachelor’s degree from an accredited institution is required.
  • Minimum of 8 years of progressive legal and/or tax experience in transfer pricing controversy at a major law firm, accounting firm or Fortune 100 company.
  • Must be legally authorized to work in the United States without sponsorship.

Position Criteria:

  • Outstanding litigation-focused issue and opportunity recognition skills.
  • Extensive knowledge of transfer pricing and valuation from a litigation perspective.
  • Demonstrated project management skills.  Must have the ability to prioritize and manage multiple projects at the same time, while adhering to strict time deadlines.
  • Ability to mentor and teach transfer pricing controversy team on global technical issues and trends.
  • Enthusiasm to learn, including the ability to research and master a broad array of complex transfer pricing technical topics.
  • Strong ability to influence thinking and gain acceptance of others in sensitive or adversarial situations.

Preferred Qualifications:

  • Juris Doctor (J.D.) or Masters of Taxation preferred.

We make what matters work. Everywhere you look—from the technology and machinery that surrounds us, to the critical services and infrastructure that we depend on every day—you’ll find one thing in common. It all relies on power. That’s why Eaton is dedicated to improving people’s lives and the environment with power management technologies that are more reliable, efficient, safe and sustainable. Because this is what matters. We are confident we can deliver on this promise because of the attributes that our employees embody. We’re ethical, passionate, accountable, efficient, transparent and we’re committed to learning. These values enable us to tackle some of the toughest challenges on the planet, never losing sight of what matters.

Job: Finance/Accounting

Region: North America – US/Puerto Rico
Organization: Corporate Sector

Job Level: Manager
Schedule: Full-time
Is remote work (i.e. working from home or another Eaton facility) allowed for this position?: No
Does this position offer relocation?: Relocation from within United States and / or Puerto Rico
Travel: Yes, 10 % of the Time