· The Manager Transfer Pricing role comes with a well-rounded tax or accounting professional that can work as part of a team who is proactive with the ability to assist in managing changing priorities in a dynamic and fast paced environment. The role will support the Global Tax Planning & Strategy group as well as the Global reporting & Compliance group in providing real-time analysis and issue identification related to transfer pricing consequences around the globe with main focus on Europe. The role must be proactive in dealing with tax related issues, and must be able to maintain cross functional working relationships.
· To assist in managing the global transfer pricing position of the group with focus on Europe.
· To assist in providing transfer pricing guidance on business and tax initiated projects at corporate or within operating affiliates
· Assisting in setting and maintaining Global transfer pricing policies, including intercompany pricing methodologies, intercompany transaction policies, cross border master transfer pricing guidelines, documentation policies
· Assist in accurate and complete identification and analysis of any transfer pricing risks and opportunities and ensuring timely and complete communication thereof to the relevant identified stakeholders
· Pro active assistance on working with corporate and business areas on relevant transfer pricing tax issues/ opportunities, understanding and aligning tax requirements and providing tax technical support
· Assisting in developing of a Transfer pricing strategic view for the group and provide guidance to various corporate departments and operational entities on tangible implementation measures and execution thereof.
· Assisting in maintaining contemporaneous documentation of transfer pricing methods and creating any relevant tax documentation, correspondence for assigned projects and tasks, including BEPS proof documentation.
· Assisting to ensure Global compliance with all applicable transfer pricing rules, cases and practices
· To document transfer pricing (uncertain) positions including contributions to FIN 48 documentation calculations and analysis
· Assisting in documenting and communicating all transfer pricing tax implications of transactions and tax positions for company to income tax reporting and compliance function
· Monitor tax legislation for impact on operations and recommend actions/strategies to implement in order to position the company in the most tax advantageous position
· Assist and coordinates transfer pricing audit defenseLead/assist in any negotiation of unilateral of bi lateral APA’s or rulings
· Assist in any negotiations/conclusions/implementation of any international Mutual Agreement Procedures (MAP) leading to corresponding adjustments within the Group
· Work with Transfer Pricing Desk on appropriate explanation, specifications and documentation of all transfer pricing charges.
· Contribute to team building and contribute to technical training of Group Fiscal. Contribute to tax awareness/appreciation within the Group
Knowledge & Experience:
· Recognized professional qualification/advanced degree in Tax, Finance, Law with minimum of 3 -5 years of experience at Corporate or Big 4. Experienced in transfer pricing tax planning and structuring
· Strong know how and experience in developing, managing, monitoring and improving global transfer pricing strategies, policies, documentation and tax audit defense files
· Minimum education level: academic tax education or HEAO (or alike)
· Strong know how and experience in developing transfer pricing and supply chain tax planning initiatives
· Experience with tax audit defense files and transfer (cross border) pricing audits
· Basic proficiency in Microsoft office products including relevant work experience in excel or other spreadsheet based software
· in-house experience is desirable
· fluent in English, Dutch is desirable
· Excellent English (both written and spoken).
· Personal Characteristics
· Responsibility, Accountability;
· Pragmatic, problem solver
· Team member;
· Ability to work in a fast changing environment;
· Ability to prioritize and meet deadlines.
Skills & Abilities:
· Strong technical knowledge of Global and EU transfer pricing regulations
· Strong analytical skills and attention for detail
· Strong managerial skills, team player; able to create relationships
· Problem solver; decision taker
· Ambitious, flexible, highly motivated, energetic, hard worker