Transfer Pricing has quietly become one of the most strategically important areas within the tax profession.

As multinational organisations navigate increasing regulatory scrutiny, evolving supply chains and complex cross-border structures, demand for experienced Transfer Pricing professionals continues to grow. Yet across Europe, a structural problem has begun to emerge. There is a clear shortage of talent at the Transfer Pricing Manager level.

This is the critical layer within most TP teams as these are the professionals responsible for leading projects, managing stakeholder relationships, overseeing documentation programmes and mentoring junior staff.

And right now, the pipeline feeding that level is thinner than many organisations expected.

The Missing Middle

Historically, the career pathway within Transfer Pricing has followed a familiar structure:

Intern → Associate → Senior Associate → Manager → Director

But the progression through this ladder has been disrupted.

One of the most significant contributing factors traces back to the pandemic. During COVID-19, recruitment across professional services slowed significantly, particularly at graduate and entry-level positions. Fewer junior professionals entered the profession during those years, creating a smaller cohort progressing through the system today.

Several years on, the consequences are becoming clear because the professionals who would normally now be reaching Manager and Senior Manager level simply aren’t available in the numbers firms expected.

This has created what many tax leaders are now describing as a “missing middle” in Transfer Pricing teams. While demand has continued to grow, supply has tightened.

Global initiatives such as OECD BEPS reforms, enhanced transparency requirements and evolving international tax rules have elevated Transfer Pricing from a technical tax discipline to a strategic function within multinational organisations.

Today TP sits at the intersection of:

• international tax strategy
• supply chain structuring
• intellectual property planning
• regulatory compliance

As a result, organisations increasingly need professionals who combine technical expertise with commercial judgement and stakeholder management and clearly these are capabilities that typically develop at the Manager level.

A Global Talent Market

One distinctive feature of Transfer Pricing careers is their international mobility. Because TP frameworks are largely aligned globally, experienced professionals can often move between jurisdictions relatively easily. As a result, the talent market has become increasingly international.

Across Europe we are currently seeing strong demand for experienced professionals in locations such as Amsterdam, Dublin, Stockholm, to name but a few. Here are a few examples of roles Meraki Talent are currently headhunting.

For ambitious Transfer Pricing specialists, this presents an opportunity to build careers in highly international teams working with multinational clients.

How organisations are responding

Faced with a shortage at Manager level, organisations are increasingly adapting how they build their Transfer Pricing teams.

Several approaches are emerging. Accelerated development programmes are becoming more common than ever, with firms investing in leadership training and project exposure to help strong Senior Associates step into Manager roles earlier.

Broader hiring strategies are also evolving. Some organisations are bringing professionals into Transfer Pricing from adjacent disciplines such as International Tax, Economics, Valuations or Financial Advisory, where analytical and commercial skillsets can translate well.

At the same time, firms are placing greater emphasis on internal training and capability building, recognising that developing talent internally may be more sustainable than relying solely on external hiring.

Finally, many organisations are embracing international mobility, widening their search across European markets to access a broader pool of experienced professionals.

A Market Defining Moment

For employers, the shortage of Transfer Pricing Managers presents a genuine challenge, but this highlights a broader lesson: the traditional talent pipeline cannot now always be relied upon.

Investment in training, broader hiring strategies and international mobility will all play a role in rebuilding the Manager-level cohort that Transfer Pricing functions depend on.

For professionals working in Transfer Pricing, however, the current market represents a significant opportunity. The combination of strong demand, increasing global complexity and a thinner mid-career pipeline means that experienced specialists are entering one of the most dynamic hiring markets the discipline has seen in recent years.

For organisations looking to strengthen their Transfer Pricing capability, the ability to identify, develop and retain that talent may well become a defining competitive advantage.

If you want to discuss these issues further, please join me on LinkedIn. or email alice.hudson@merakitalent.com