Senior Manager Transfer Pricing (f/m/div)

In this Senior Manager Transfer Pricing role at Infineon HQ, you drive the global transfer pricing strategy and ensure compliant intercompany pricing. You’ll lead advisory on complex M&A and restructurings, supervise documentation and audits, and train cross-functional teams worldwide. With a focus on IP valuation and regulatory changes, you help Infineon scale its global operations while aligning with tax strategy. This pivotal role blends strategic leadership with hands-on TP execution to enable sustainable growth.

• Develop and continuously optimize the group’s global transfer pricing strategy and its implementation
• Ensure intercompany transactions are priced at arm’s length
• Serve as primary contact for business units and global subsidiaries, providing guidance and training on transfer pricing policies
• Advise on complex group-wide M&A and intra-group restructurings regarding TP, including IP and business valuation for tax purposes
• Manage tax audits, MAPs, and APAs to resolve transfer pricing disputes
• Coordinate and support preparation of TP documentation (master file, local files, country-by-country reporting)
• Draft and review intercompany agreements to ensure TP compliance
• Monitor impact of TP regulatory changes on structure and operations

• A university degree in economics, business administration, or law; an advanced qualification is preferred
• At least 6 years of transfer pricing experience in consulting (ideally Big Four) or in a capital market-oriented, globally active company
• Strong knowledge of TP in Germany and internationally (OECD, BEPS, MAPs, APAs)
• Legal knowledge related to intercompany agreements; IP and business valuation are advantageous
• Significant practical project management experience; strong analytical and problem-solving skills; assertiveness and teamwork
• Strong English communication skills; German a plus

• Significant project management experience
• Analytical and complex problem-solving abilities
• Assertiveness
• Transfer pricing knowledge across Germany and international regimes
• OECD BEPS framework, MAPs and APAs
• IP and business valuation for tax purposes