Associate Director, Transfer Pricing & Tax Operations (Hybrid - Rahway, NJ)

Job Description

Position Overview
The Associate Director, Transfer Pricing will be a key member of our Company's Corporate Tax organization, responsible for supporting the development, implementation, monitoring, documentation, and defense of our Company's global transfer pricing policies.

This role is well suited for an analytical, business-oriented tax and finance professional who is comfortable working with complex financial and operational data, developing practical models, and translating analysis into clear insights that support business and tax decision-making. The successful candidate will have a strong foundation in accounting, finance, and/or tax, with an appreciation of transfer pricing principles, U.S. transfer pricing rules under Section 482, and broader international tax considerations.

The individual will partner closely with colleagues across Tax, Finance, Accounting, Treasury, Legal, Manufacturing, R&D, Commercial, and other business functions. This role requires someone who can understand the business, analyze data thoughtfully, build simple and effective models, communicate clearly, and work collaboratively in a highly cross-functional environment.

The ideal candidate will be intellectually curious, highly organized, personable, and team-oriented, with strong analytical judgment and the ability to simplify complex information for practical business use.

Key Responsibilities

• Support the development, implementation, monitoring, and defense of our Company's global transfer pricing policies for intercompany transactions.

• Analyze complex financial, accounting, operational, and legal entity data to support transfer pricing conclusions, business decisions, and audit-ready documentation.

• Build practical financial models and analytical tools to evaluate legal entity profitability, intercompany pricing outcomes, service allocations, royalty charges, manufacturing results, and other transfer pricing matters.

• Translate large or complex data sets into simple, clear, and actionable insights for Tax, Finance, and business stakeholders.

• Coordinate with U.S. and non-U.S. Tax, Finance, Accounting, Treasury, Legal, Manufacturing, R&D, Commercial, and other business teams to execute intercompany pricing policies and address transfer pricing issues.

• Support transfer pricing analyses related to manufacturing, product supply, distribution, R&D services, manufacturing services, management service fees, intercompany licenses, royalties, and other cross-border arrangements.

• Monitor and validate transfer pricing results, including legal entity margins, functional income statements, service charges, allocation methodologies, and true-up calculations.

• Assist in evaluating intercompany agreements and ensuring that contractual terms are aligned with business substance, accounting results, and transfer pricing documentation.

• Support U.S. and global transfer pricing documentation, audit defense, tax controversy, and responses to information requests from tax authorities.

• Partner with internal stakeholders and external advisors to gather data, understand business facts, prepare analyses, and develop supportable transfer pricing positions.

• Identify opportunities to improve transfer pricing processes, reporting, controls, data quality, and use of technology.

• Communicate complex transfer pricing, accounting, and international tax concepts in a clear and practical manner to both tax and non-tax audiences.

Required Qualifications

• Bachelor’s degree in accounting, Finance, Tax, Economics, Business, or a related field.

• Minimum of 7 years of relevant experience in corporate tax, public accounting, transfer pricing, international tax, finance, accounting, economic consulting, or business advisory roles.

• Strong accounting and financial analysis background, including the ability to understand income statements, cost structures, legal entity financials, allocations, margins, and profitability.

• Demonstrated ability to work with complex data, identify key issues, build simplified models, and use analysis to support business and tax decisions.

• Working knowledge of transfer pricing principles, including the arm’s-length standard, functional analysis, comparability, intercompany pricing methods, documentation, and audit defense.

• High-level understanding of U.S. transfer pricing rules under Section 482 and related concepts.

• Appreciation of broader international tax considerations relevant to multinational businesses, including cross-border transactions, royalties, services, legal entity structures, withholding tax considerations, and global tax compliance.

• Strong Excel and financial modeling skills, with the ability to organize, analyze, and summarize large data sets.

• Strong written and verbal communication skills, including the ability to present complex analyses in a clear, concise, and business-friendly way.

• Ability to manage multiple priorities, exercise sound judgment, and deliver high-quality work in a deadline-driven environment.

• Strong interpersonal skills and demonstrated ability to work effectively in a collaborative team environment.

Preferred Qualifications

• CPA, Chartered Accountant, master’s degree in accounting or taxation, MBA, JD, or similar advanced credential.

• Experience in transfer pricing, international tax, corporate tax planning, tax accounting, finance, or operational transfer pricing.

• Experience in the pharmaceutical value chain analysis, life sciences, healthcare, manufacturing, or technology sector.

• Experience analyzing intercompany transactions involving manufacturing, product supply, distribution, R&D services, management services, royalties, licenses, intangible property, or business development arrangements.

• Experience supporting transfer pricing documentation, audit defense, intercompany agreement reviews, or operational transfer pricing processes.

• Experience using SAP, Business Objects, Power BI, Alteryx, or similar financial reporting, data analytics, or visualization tools.

• Interest in using technology, automation, and analytics to improve transfer pricing processes and controls.

Key Skills and Competencies

• Strong analytical thinking and problem-solving skills

• Comfort working with complex data and financial information

• Ability to build simple, practical models from complicated facts

• Strong accounting and finance foundation

• Business acumen and curiosity about how the company operates

• Practical understanding of transfer pricing principles

• Appreciation for U.S. and international tax rules

• Strong Excel, modeling, and data organization skills

• Clear and concise communication style

• Ability to explain technical concepts to non-tax stakeholders

• Strong relationship-building and business partnering skills

• Collaborative, approachable, and team-oriented working style

• Attention to detail with ability to see the broader picture

• Sound judgment, ownership, and accountability

• Ability to manage competing priorities and drive work forward

Success Profile
The ideal candidate will be someone who enjoys working at the intersection of tax, finance, accounting, data, and business operations. This person should be comfortable taking complex financial or operational information, organizing it in a thoughtful way, and developing simple models or analyses that help the team understand the issue and make better decisions.

The successful candidate does not need to be a narrow transfer pricing technical specialist only. Rather, this person should be a well-rounded, analytical professional with strong accounting instincts, sound business judgment, and the ability to learn and apply transfer pricing principles in a practical way.

This individual should be collaborative, personable, and able to work well with colleagues across Tax, Finance, Legal, Manufacturing, R&D, Commercial, and external advisor teams. The role requires someone who can ask good questions, listen carefully, build trust, and help turn data and business facts into supportable transfer pricing outcomes.

Required Skills:

ASC 740, Budget Preparation, Corporate Tax Compliance, Detail-Oriented, Ideas Generator, International Tax Consulting, International Tax Planning, Preparation of Financial Reports, Relationship Building, Tax Compliance, Tax Law, Tax Minimization, Tax Strategies, Team Leadership, Transfer Pricing

Preferred Skills:

Current Employees apply HERE

Current Contingent Workers apply HERE

US and Puerto Rico Residents Only:

Our company is committed to inclusion, ensuring that candidates can engage in a hiring process that exhibits their true capabilities. Please click here if you need an accommodation during the application or hiring process.

As an Equal Employment Opportunity Employer, we provide equal opportunities to all employees and applicants for employment and prohibit discrimination on the basis of race, color, age, religion, sex, sexual orientation, gender identity, national origin, protected veteran status, disability status, or other applicable legally protected characteristics. As a federal contractor, we comply with all affirmative action requirements for protected veterans and individuals with disabilities. For more information about personal rights under the U.S. Equal Opportunity Employment laws, visit:

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We are proud to be a company that embraces the value of bringing together, talented, and committed people with diverse experiences, perspectives, skills and backgrounds. The fastest way to breakthrough innovation is when people with diverse ideas, broad experiences, backgrounds, and skills come together in an inclusive environment. We encourage our colleagues to respectfully challenge one another’s thinking and approach problems collectively.

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The salary range for this role is

$129,000.00 - $203,100.00

This is the lowest to highest salary we in good faith believe we would pay for this role at the time of this posting. An employee’s position within the salary range will be based on several factors including, but not limited to relevant education, qualifications, certifications, experience, skills, geographic location, government requirements, and business or organizational needs.

The successful candidate will be eligible for annual bonus and long-term incentive, if applicable.

We offer a comprehensive package of benefits. Available benefits include medical, dental, vision healthcare and other insurance benefits (for employee and family), retirement benefits, including 401(k), paid holidays, vacation, and compassionate and sick days. More information about benefits is available at

You can apply for this role through (or via the Workday Jobs Hub if you are a current employee). The application deadline for this position is stated on this posting.

San Francisco Residents Only: We will consider qualified applicants with arrest and conviction records for employment in compliance with the San Francisco Fair Chance Ordinance

Los Angeles Residents Only: We will consider for employment all qualified applicants, including those with criminal histories, in a manner consistent with the requirements of applicable state and local laws, including the City of Los Angeles’ Fair Chance Initiative for Hiring Ordinance

Search Firm Representatives Please Read Carefully
Merck & Co., Inc., Rahway, NJ, USA, also known as Merck Sharp & Dohme LLC, Rahway, NJ, USA, does not accept unsolicited assistance from search firms for employment opportunities. All CVs / resumes submitted by search firms to any employee at our company without a valid written search agreement in place for this position will be deemed the sole property of our company. No fee will be paid in the event a candidate is hired by our company as a result of an agency referral where no pre-existing agreement is in place. Where agency agreements are in place, introductions are position specific. Please, no phone calls or emails.

Employee Status:

Regular

Relocation:

Domestic

VISA Sponsorship:

No

Travel Requirements:

No Travel Required

Flexible Work Arrangements:

Hybrid

Shift:

Not Indicated

Valid Driving License:

No

Hazardous Material(s):

N/A

Job Posting End Date:

09/14/2026

*A job posting is effective until 11:59:59PM on the day BEFORE the listed job posting end date. Please ensure you apply to a job posting no later than the day BEFORE the job posting end date.