The Transfer Pricing Manager will be responsible for ensuring compliance with transfer pricing regulations across multiple jurisdictions where the company operates including Europe, Africa, the Middle East, USA and Australia. The role involves preparing transfer pricing documentation, conducting or coordinating benchmarking studies, identifying improvement areas, implementing automation solutions and ensuring alignment with the company’s tax governance framework.
Key Responsibilities
Transfer Pricing Documentation:
Prepare and maintain transfer pricing documentation including Local Files, Master Files, and disclosure forms in accordance with OECD guidelines and local regulations.
Ensure timely preparation and submission of documentation to meet statutory deadlines.
Prepare and maintain comprehensive transfer pricing transmittal letters ensuring coverage of the position and associated risks.
Confirming alignment with group policies & procedures and ensuring consistency across jurisdictions.
Oversee and ensure local jurisdictional compliance with regulatory requirements in all operative jurisdictions for Transfer Pricing, CbCR and related disclosures.
Benchmarking Analysis:
Conduct benchmarking studies to determine appropriate arms length ranges for intra-group transactions.
Identify tools and methodologies to enhance benchmarking analysis accuracy and efficiency.
Coordinate with external consultants where required for conducting benchmarking studies.
Perform regular transfer pricing risk assessments to identify and address potential compliance risks.
Improvement & Automation Assistance to Tax Governance Lead:
Identify gaps and areas for improvement in the current transfer pricing processes through comprehensive gap assessments.
Propose and implement automation solutions to streamline documentation and benchmarking processes.
Implement tools in respect of transfer pricing compliance to enhance data reporting, automate processes, and support optimisation, accuracy, efficiency, and effectiveness of the tax function as a whole.
Collaborate with the Tax Governance and Risk Lead to implement transfer pricing projects.
Provide inputs for maintaining effective governance structures and managing transfer pricing risks across jurisdictions.
Ensure consistency in transfer pricing methodologies applied across different regions.
Monitor, determine, and manage transfer pricing liabilities of Group entities.
Stakeholder Collaboration & Management:
Work closely with regional tax teams, finance departments, and external advisors to ensure accurate implementation of transfer pricing policies.
Assess, appoint, manage, and supervise consultants for specialized transfer pricing tasks if needed and instructed.
Provide training, guidance, and set performance indicators for the transfer pricing compliance function.
Handle direct contacts and negotiations with local authorities, including review and recommendations.
Ensure seamless integration with the broader Group Tax Team (Compliance, Governance & Risk, Legal & Advisory) for interdependent projects and tasks.
Reporting & Financial Analysis:
Prepare and work on group transfer pricing reporting and financial analysis to ensure accurate and timely reporting of transfer pricing positions and liabilities.
Review and analyze transfer pricing provisions and accruals to ensure compliance and accuracy.
Tax Audits & Disputes:
Manage transfer pricing audits and disputes in various jurisdictions.
Respond to inquiries from tax authorities and ensure all audit requirements are met.
Represent the organization during transfer pricing audits or litigation to protect the organization’s interests.
Preferred Qualification And Experience
Bachelors degree in Accounting, Finance, Economics, Law, or related field.
Advanced tax qualifications (e.g., ADIT, CTA, LLM or Master’s in International Taxation) preferred.
Minimum of 5 years of transfer pricing experience, preferably in a Big4 firm or large multinational enterprise with exposure to multiple jurisdictions.
Strong understanding of OECD guidelines, BEPS action plans, local transfer pricing regulations, and best practices across jurisdictions including Europe, Africa, the Middle East, USA and Australia. P
Analytical skills, attention to detail, effective communication, project management, and proficiency in relevant software/tools for benchmarking and documentation.
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