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Transfer Pricing Specialist

São Paulo

EBANX is the leading payment platform connecting global companies with customers from the fastest-growing digital markets in the world. 

Since the beginning of our journey, we have had one mission: to provide global access for everyone. We believe that transforming challenges into opportunities and making the impossible part of the journey is crucial! That's precisely why we created a payment technology that builds bridges between people and businesses every day in 29 rising markets across the globe. 

We call ourselves ebankers, we are global thinkers, we value diversity, we foster creativity and we work hard to connect businesses and people worldwide through payments. Let's make history together?

We are seeking a Transfer Pricing Specialist with solid experience in cross-border operations and in-depth knowledge of OECD guidelines, including the application of the arm’s length principle. This professional will support the organization in analyzing, structuring, and ensuring compliance with transfer pricing policies, aligned with regulatory requirements and best practices.

You will also be responsible for:

  • Review methodologies and OECD-aligned policies prepared internally or by external advisors, ensuring compliance with the arm’s length principle.
  • Review benchmarking analyses and comparable sets prepared by external advisors (no expectation to conduct benchmarking from scratch).
  • Support the preparation and maintenance of Transfer Pricing documentation (Master File, Local File, CbCR) together with external advisors.
  • Analyze intercompany transactions involving goods, services, IP/licensing, financing flows, cost sharing, and recharges.
  • Prepare or review memos, TP position papers, and audit-ready supporting documentation.
  • Assist in managing tax audits and interactions with tax authorities related to Transfer Pricing.
Strategy & Expansion
  • Evaluate tax and transfer pricing impacts of new business models, market entries, and operational expansions, especially in payments, remittances (CNR), and eFX structures.
  • Support design and refinement of supply chain and value chain allocation models, ensuring alignment with functional / risk profiles.
  • Work with Product, Finance, Legal, Treasury, and Business Development to translate business initiatives into compliant and efficient intercompany flows.
  • Monitor regulatory and BEPS developments affecting global intercompany pricing, profit allocation, DEMPE/IP, and digital services models.
  • Contribute to strategic restructuring initiatives .

Main requirements for this position:

  • Solid experience in Transfer Pricing aligned to OECD guidelines.
  • Ability to review methodologies, comparables, and documentation (not only execute them).
  • Experience navigating complex intercompany flows (services, IP/licensing, financing, cost sharing).
  • Strong analytical and problem-solving skills; ability to convert business models into TP logic.
  • Fluent English (written and spoken) — ability to interact with global teams and advisors.
  • Degree in Law, Economics, Accounting, Business, or related field.

Nice to Have
  • Experience in digital / fintech / payments or cross-border business models.
  • Prior experience working with international expansion, regulatory analysis, or supply chain structuring.
  • Experience from Big Four (PwC/EY/Deloitte/KPMG) or in-house TP at a multinational.
  • Comfortable communicating with non-tax stakeholders and senior leadership.

EBANX offers:

  • Spanish, English, and Portuguese classes;
  • Meal Allowance;
  • Transportation voucher (if needed);
  • WAVES - Program of goals and results (variable compensation);
  • EBANX Play - Wellness (Gympass, e-Sports, SESC );
  • EBANX Education: financial support for undergraduate, graduate, and MBA programs so you can develop important skills for your career;
  • EBANX Skills: budget for workshops and courses;
  • EBANX Flexible: Birthday Day Off;
  • Semi-flexible hours (8 hours a day - Monday to Friday);
  • EBANX Family: Daycare assistance, extended leave for caregivers and support program for children and pregnant women;
  • EBANX Health: Health and Dental Insurance, with subsidy for dependents and medicine subsidy for ebankers;
  • Life Insurance: Life Insurance 100% paid by EBANX;
  • Blue Club: Exclusive discount for ebankers in bakeries, restaurants, courses, electronics stores, and more!

Follow us on LinkedIn and check out our Instagram to learn more about the #ebanxlife.

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