Senior Transfer Pricing Manager

Principal responsibilities:

Work with the local teams and advisors to understand the business and any changes to ensure TP implications are appropriately considered (e.g. changes in business model, entering into new locations, etc.).

Support/lead on various business initiatives and projects to ensure TP solutions are implemented properly. Work with other teams within the Group Tax, Treasury and Customs function to ensure that any related TP issues are considered more holistically.

Support the development, implementation and maintenance of global transfer pricing policies and procedures.

Keep updated on developments in TP law/practice and assess their impact on the business.

Review transfer pricing documentation, transfer pricing declarations, CbCR notification, ACRs and any other transfer pricing related compliance returns and forms prepared by advisors and ensure they are filed by the required statutory deadline. Some of these may be prepared in-house.

Lead functional interviews with internal stakeholders to understand the relevant FAR.

Manage TP controversy including managing TP audits and working with advisors on mutual agreement procedure (MAP). This also includes working with the local Dyson entities and advisors to ensure that local TP audits are managed effectively and in-line with group policies.

Undertake TP planning including operational TP (leading TP automation processes) and working with advisors on APAs.

Identify potential transfer pricing risks and develop solutions to mitigate these risks.

Analyse the impact of transfer pricing policies on financial performance and provide accurate and timely transfer pricing data to other internal stakeholders.

Support year end TP processes including analysing and reviewing intercompany transfer pricing results, working out and proposing TP adjustments, as well as analysing uncertain tax provisions (UTP) arising from TP issues.

Develop and implement intercompany agreements.

Review local statutory accounts to ensure appropriate TP results are achieved and proposing TP adjustments where required. Liaise with advisors/Corporate tax team/Customs team to understand how best to put through TP adjustments.

Perform quarterly TP reviews to ensure local entities are appropriately remunerated. This includes working with the local finance and corporate tax teams to understand and verify forecasts.

Monitor inter-company transactions (including inter-company financing transactions) to ensure appropriate TP positions are taken and identify and rectify issues on a timely basis.

Review existing TP processes and implement improvements and efficiencies where appropriate.

Provide ad-hoc TP support to internal stakeholders and/or corporate tax/customs teams as required.

Build and manage relationships with Dyson's advisors, internal stakeholders (finance, legal, treasury, other tax and customs teams) and shared service teams to perform the abovementioned activities.

Provide guidance and support to other members of the team.

Requirements:

Bachelor's Degree in Accounting, Finance, or Business/Economics-related discipline preferred. CPA and/or advanced taxation certification is a plus.

10+ years experience in public accounting and/or corporate environment. Having both Big 4 and in-house experience (especially in FMCG) is a plus.

Prior experience dealing with TP issues in multiple jurisdictions.

Prior experience with APAs, MAPs, controversy management and familiar with application of transactional profit split.

Strong understanding of OECD TP guidelines. Some familiarity with Amount B is a plus.

Ability to multi-task, handle deadlines and implement practical solutions.

Ability to connect the dots and adopt a big picture business and commercial view.

Keen learner and willingness to do the ground work.

Keen interest in and ability to grasp economic/business concepts and TP laws/regulations of other countries.

Comfortable with technology (e.g. SAP, OneStream, Alteryx).

Team player who is willing to help, share and guide others.