Transfer-Pricing Operating Model Expert — Global Medical Devices

The mandate

Five acquisitions have left the group with inconsistent distributor margins, overlapping R&D service charges, unsupported management allocations and IP returns that do not follow actual decision-making. The defined task is to design a single prospective operating model that can calculate, book, monitor and explain material intercompany outcomes without rewriting historical tax returns or conducting a broad legal-entity simplification.

The required artefacts are a value-chain and functional-evidence map, policy architecture, entity-method matrix, calculation specifications, intercompany agreement requirements, monthly monitoring dashboard, true-up protocol and implementation control book. The design must distinguish medical-device regulatory ownership from R&D performance, map decision makers rather than job titles, and convert tax policy into entries the controllers can reproduce.

Milestone one on 16 October 2026 is the agreed fact pattern and risk-ranked policy-gap report. By 13 November, milestone two will deliver selected methods, tested-party decisions and quantified policy alternatives; a prototype calculation and draft agreements are due 11 December; final delivery on 15 January 2027 comprises a shadow close, exception resolution, approved control matrix and operator training.

Work is accepted when the Group Tax Director, controller and regional finance leads can reproduce sampled charges from governed source data, every material entity has an approved method and agreement route, dashboard exceptions reconcile to booked results, and independent tax counsel finds no unresolved high-risk inconsistency between facts and policy. Final acceptance also requires controllers to execute the shadow close without consultant-operated spreadsheets.

The client will provide legal agreements, local files, trial balances, headcount and activity data, product flows, R&D governance records and named regional tax contacts. Legal privilege and tax judgments remain with the group and its counsel; the expert may propose policy and specifications but will not negotiate with tax authorities, redesign the ERP or sign returns.

Why this is external work

The in-house tax team has inherited the policies and cannot easily distinguish deliberate positions from acquisition residue. It also lacks spare capacity to trace operational facts across R&D, regulatory and supply-chain owners while meeting filing obligations. An external specialist gives the CFO a politically neutral design and an acceptance-tested bridge from technical policy to monthly finance execution.

What you will own

• Trace economically significant decisions, assets, risks and people across the product lifecycle, documenting contradictions between contracts, interviews and observed governance.
• Select and defend the transfer-pricing method for each material transaction class, with rejected alternatives and sensitivity to changing operational facts.
• Specify controller-ready calculations for product distribution, contract R&D, IP access, manufacturing support, central services, guarantees and financing.
• Design a governed data model that maps source fields, allocations, foreign exchange, materiality, review evidence and retained calculation versions.
• Draft the required commercial terms for intercompany agreements and identify operational behaviours that must change before those terms are supportable.
• Run a shadow monthly close, reconcile calculated outcomes to ledger postings and resolve exceptions through a documented tax-and-finance decision forum.
• Transfer the policy manual, entity matrix, calculation specifications, monitoring dashboard and annual true-up calendar to trained client owners.

Candidate qualifications

• Designed and implemented a multinational transfer-pricing operating model across IP, R&D, manufacturing, distribution, services and financing flows.
• Can show how DEMPE or comparable functional evidence changed an initial policy conclusion, including the people, decisions and records examined.
• Converted technical methods into repeatable monthly calculations embedded in controller workflows rather than year-end consultant adjustments.
• Led policy integration after multiple acquisitions and resolved conflicts among legacy agreements, actual conduct, system data and local documentation.
• Defended tested-party selection, comparables, allocation keys and true-up mechanics before tax authorities or independent counsel in several jurisdictions.
• Delivered a shadow close whose calculated charges reconciled to ledgers and were subsequently operated by internal tax and finance teams.

Non-negotiables

• Available for the Amsterdam-centred four-month sprint and milestone travel to Zurich and Dublin.
• Independent of the group's statutory auditor and free of conflicting representation in a current transfer-pricing dispute involving the group.
• Will work to reproducibility and counsel-review acceptance tests, not stop at policy slides or benchmarking reports.
• Has directed global transfer-pricing implementation at enterprise director or partner-equivalent level.

1. 49 words maximum. Describe one operating fact that caused you to reject an otherwise plausible transfer-pricing method.
2. 49 words maximum. How would you prove that a controller can reproduce an intercompany charge without your model operator?
3. 49 words maximum. Which three datasets would you request first to distinguish IP ownership from actual value-creating control?