Manager - Transfer Pricing Controversy (EMEA)

Job Description

Eaton's Corporate Division has an opening for :


Manager - Transfer Pricing Controversy (EMEA)


Location: Open to Europe - close to an EATON location


Join Eaton and help us provide energy-efficient solutions that have a real impact on the environment. We make what matters work. Find out more on


The Manager – Transfer Pricing Controversy (EMEA) position is a dynamic position that supports the Transfer Pricing Strategy group.  The position will encompass responsibility for developing, documenting, and implementing best practices for defending Eaton’s worldwide transfer pricing strategy in the EMEA region.  This role will lead and manage a team of transfer pricing professionals based in Budapest, Hungary, but may be primarily located in any EMEA Eaton location.



Your key deliverables :


  • Lead tax audit defense for EMEA entities, which includes developing globally consistent  and strategic responses to inquiries in a timely and concise manner, reviewing and analyzing government positions to provide strategic defense options to TP leadership, developing and proposing strategies to reach resolution with the tax authorities, and managing service provider engagements and fees.
  • Proactively identify and manage transfer pricing risks by ensuring consistent worldwide application of transfer pricing practices and documentation for Eaton’s global intercompany transactions (tangibles, intangibles, financial, and services).
  • Identifies transfer pricing issues and proposes strategies to mitigate risk
  • Keeps abreast of BEPS developments and identifies impact to the company 
  • Reviews required global transfer pricing documentation
  • Develop and document best practices for consistently defending Eaton’s worldwide transfer pricing strategy in the EMEA region and elsewhere.
  • Participate with global controversy team in developing globally consistent strategies
  • Liaise with strategy team to provide input on proposed structures to ensure compliance with local regulations in EMEA 
  • Lead, manage and train the EMEA tax controversy team located in Budapest, Hungary.
  • Collaborate with Planning, Operations, and Documentation teams to effectively manage transfer pricing risks, identifying areas for continued improvement, and incorporate lessons learned.


Are you?


A professional with a problem solving mindset to adapt and drive improvements in process, tools, and organization; and with a focus on transfer pricing controversy – than please apply.


  • Bachelor’s Degree in Economics, Finance, or Accounting or a Master’s degree in economics, business or law; an LL.M. or similar advanced legal degree is preferred
  • German language knowledge would be an advantage
  • Minimum of seven years of experience in Transfer Pricing; and minimum of five years of experience reviewing the work, and assisting in the training, of junior employees in transfer pricing analysis
  • The ideal candidate would possess transfer pricing experience with a Big Four accounting firm/boutique transfer pricing firm or large multi-national company


What Eaton offers:

Challenging projects in dynamic collaborative team

Excellent working environment – safety and ethics is really important for us

Culture & Values - Eaton is more than the products we invent and produce – the way we do business is just as important. At Eaton, our values and culture define who we are – both individually and as an organization – and direct our activities every day.

Learning & Development- We invest in our employees for the long term – not just with salary and benefits, but with ongoing learning and development opportunities made available through Eaton University.


Eaton’s mission is to improve the quality of life and the environment through the use of power management technologies and services. We provide sustainable solutions that help our customers effectively manage electrical, hydraulic, and mechanical power – more safely, more efficiently, and more reliably. Eaton’s 2019 revenues were $21.4 billion, and we sell products to customers in more than 175 countries. We have approximately 101,000 employees. For more information, visit


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: Europe, Middle East, Africa
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?: Yes
Does this position offer relocation?: No
Travel: Yes, 10 % of the Time