Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy

Tax Planning & International Tax

• Lead EMEA tax planning initiatives for assigned jurisdictions.
• Identify and evaluate tax planning opportunities arising from business operations, restructurings and financing activities.
• Develop technically supportable and audit-defensible positions on international tax matters.
• Present tax planning opportunities, risks and recommendations to senior tax leadership.
• Support legal entity rationalizations, restructuring projects and operating model changes.
• Provide technical advice on international tax issues including cross-border transactions, withholding taxes and treaty application.
• Monitor developments in OECD guidance, EU tax developments and local legislation.

Transfer Pricing

• Lead transfer pricing governance for financing, treasury, leasing, intellectual property and other intercompany transactions.
• Oversee development and maintenance of transfer pricing policies in accordance with OECD Guidelines and local requirements.
• Coordinate transfer pricing documentation and defense strategies globally in collaboration with the Transfer Pricing team.
• Support implementation of transfer pricing policies across business units and jurisdictions.
• Ensure appropriate governance and controls are maintained over intercompany arrangements.

APAs & MAPs

• Lead and manage Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).
• Develop technical positions and submissions for tax authorities.
• Coordinate internal stakeholders and external advisors throughout negotiations and dispute resolution processes.
• Support resolution of double taxation and cross-border transfer pricing disputes.

Tax Controversy & Advocacy

• Lead the EMEA Tax Controversy Program for assigned jurisdictions.
• Manage tax inquiries, audits, appeals, litigation and dispute resolution matters.
• Develop audit defense strategies and supporting documentation.
• Prepare technical memoranda and supporting evidence to defend material tax positions.
• Coordinate responses with tax authorities and external advisors.
• Maintain controversy assessments and reporting processes for management and compliance purposes.
• Lead complex controversy matters involving transfer pricing, international tax and financing structures.
• Assess legislation and develop technical and legal arguments supporting the Company's positions, including matters involving EU law and OECD principles.

Leadership & Stakeholder Management

• Lead complex multi-jurisdictional projects involving Tax, Treasury, Finance, Legal and business leadership.
• Build and maintain strong relationships with tax authorities, external advisors and internal stakeholders.
• Present complex technical matters clearly and effectively to senior management.
• Promote strong tax governance, documentation and risk management practices across the region.

Requirements

Experience

• 10+ years of relevant experience in international tax, transfer pricing, tax planning and tax controversy within a multinational corporation, Big Four accounting firm and/or law firm.
• Significant experience managing complex cross-border tax matters across multiple jurisdictions.
• Experience with APAs, MAPs, tax audits, controversy matters and dispute resolution.
• Strong experience in transfer pricing, OECD Guidelines and transfer pricing governance.
• Experience with cross-border financing structures, treasury-related tax issues, withholding taxes and treaty interpretation.
• Experience working with tax authorities and managing external advisors.
• Experience supporting multinational operations across EMEA.

Education & Professional Qualifications

• Degree in Law, Tax, Accounting, Finance, Business or a related discipline.
• Master's degree or advanced professional qualification in Tax, International Tax or related field preferred.
• Advanced transfer pricing qualifications and/or demonstrated expertise in OECD transfer pricing principles highly desirable.
• Strong technical knowledge of international tax, transfer pricing, OECD guidelines and tax controversy practice.

Skills & Competencies

• Excellent analytical, advocacy and problem-solving skills.
• Strong written and verbal communication skills.
• Ability to develop technically robust and commercially practical solutions.
• Proven ability to lead projects and influence stakeholders across multiple functions and jurisdictions.
• Strong relationship management skills with internal and external stakeholders.
• Fluent English required.
• German language capability is an advantage

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