Transfer Pricing Manager
Company: Allison Transmission
Location: Indianapolis
Posted on: April 2, 2026
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Job Description:
JOIN THE TEAM THAT’S POWERING PROGRESS Building cities. Driving
commerce. Fueling Progress. For over 100 years, Allison has powered
the vehicles and technology that move our world forward. What
powers us? Our employees. From the first person hired by James
Allison in 1915 to the thousands across the globe who work for
Allison today, we're driving progress everywhere because we employ
top talent worldwide. In both the Allison Transmission and Allison
Off-Highway Drive and Motion Systems business units, our team
strives to Improve the Way the World Works. Learn more about this
role and how you can begin driving your career forward! Benefits:
The below list features some of the benefits currently available.
Eligibility may be subject to the terms and conditions of governing
documents and available benefits may be subject to change at the
company’s discretion. Choice of medical plans with prescription
coverage Employer HSA contribution Dental & Vision Insurance Paid
Parental Leave Short & Long-Term Disability Other voluntary
benefits including: Critical Illness, Hospital Indemnity, Identity
Theft Protection and Pet Insurance 401K with generous Company match
& contribution Accrued Paid Time Off 12 Paid Holidays 1 Floating
Holiday Robust employee wellness program Tuition assistance program
Job Description: Job Description: The Transfer Pricing Manager is a
key role within Allison’s tax team that includes responsibilities
responsible for designing, implementing, and maintaining Allison’s
global transfer pricing framework. This includes implementing the
transfer pricing, coordinating global documentation, managing TP
audits and controversy, and partnering closely with Finance, Tax,
Legal, and Business units to ensure that intercompany transactions
are aligned with both business objectives and local regulatory
requirements. Key Responsibilities: T ransfer Pricing Strategy &
Planning · Develop and refine transfer pricing policies consistent
with the group’s operating model, value chain, and business
strategy. · Evaluate and advise on tax and transfer pricing
implications of business restructurings, supply chain changes, and
new business initiatives (e.g., new products, manufacturing
locations, distribution models). · Provide technical transfer
pricing insights to senior management to support informed
decision-making. Operational Implementation & Governanc e · Support
the design and implementation of intercompany pricing models for
tangible goods, services, IP, and financing arrangements. ·
Translate transfer pricing policies into clear, practical guidance
and processes for Finance, Accounting, and Business teams. · Work
with regional controllers and shared service centers to ensure
accurate calculation, booking, and monitoring of intercompany
charges (e.g., cost allocations, royalties, service fees,
mark-ups). · Develop and maintain robust governance, including
intercompany agreements, documentation standards, and control
frameworks. · Monitor actual margins and results versus policy
targets and recommend adjustments as needed. Documentation &
Compliance · Coordination of global transfer pricing documentation,
including Master File and Local Files, and Country-by-Country
Reporting (CbCR). · Oversee preparation and support for local
transfer pricing forms, disclosures, and related tax return
reporting. Audit Management & Controversy · Assist controllers for
transfer pricing inquiries from tax authorities across
jurisdictions. · Manage transfer pricing audits, information
requests, and dispute resolution, working with external advisors
where necessary. · Assess and quantify transfer pricing risks and
exposures; recommend and implement mitigation strategies. · Support
Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP)
processes when appropriate. Business Partnering & Cross-Functional
Collaboratio n · Collaborate with Treasury, Legal, Operations, and
Commercial teams on new intercompany arrangements and business
initiatives. · Provide training and guidance to Finance and Tax
colleagues on transfer pricing policies, changes in regulations,
and practical application. · Communicate complex transfer pricing
concepts in a clear, business-oriented manner to non-tax
stakeholders. · Assess impacts of regulatory changes on Allison
Transmission’s transfer pricing model and recommend proactive
responses Key Performance Measures: Effective/timely management of
compliance process Effective/timely communication with
internal/external customers Problem solving ability and desire to
improve current processes Qualifications: Bachelor’s degree in
Accounting, Finance, Economics, Business, or related field. ·
Professional qualification such as CPA, CTA, or equivalent, or
advanced degree in Tax, Economics, or Finance. · Experience within
the manufacturing, automotive, or industrial sectors. · Familiarity
with ERP systems (e.g., SAP, Oracle) and tax/TP software tools
Experience: 5 to 8 years of tax experience with at least 3 of
dedicated transfer pricing experience, ideally with a combination
of Big Four/consulting and in-house multinational exposure. ·
Strong technical knowledge of U.S. transfer pricing regulation,
OECD Guidelines and key transfer pricing concepts (e.g., functional
analysis, comparability, method selection, DEMPE, value chain
analysis). · Hands-on experience reviewing transfer pricing
documentation (Master File/Local File) and managing
multi-jurisdiction compliance. · Proven experience with transfer
pricing planning and implementation of intercompany policies across
multiple entities and jurisdictions. · Demonstrated experience
handling tax authority queries or audits in the transfer pricing
area. · Advanced Excel skills and comfort working with financial
data and modeling. · Excellent written and verbal communication
skills, with the ability to present complex issues clearly to
senior management. Allison Transmission is an equal opportunity
employer. We have opportunities for all qualified applicants
regardless of age, race, color, sex, religion, creed, national
origin, disability, sexual orientation, gender identity/expression
or veteran status. If you are an individual with a disability or a
disabled veteran requiring assistance and/or reasonable
accommodations reviewing any of the careers information, please
contact us at atiask4max@service-now.com . Please note that Allison
Transmission will make an offer of employment only to individuals
who have applied for a position using our official application. Be
on alert for possible fraudulent offers of employment. Allison
Transmission will not solicit money or banking information from
applicants.
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