Director, Transfer Pricing & Disputes

Responsibilities

• Leadership Team member for the Tax Planning team, including participating in global enterprise tax meetings, as well as succession planning and calibration meetings at the Tax Planning team level.
• Lead, mentor, and develop a team of 2 tax disputes and transfer pricing specialists
• Develop enterprise-level, global TP policy and risk management strategies
• Collaborate with global tax and business partners across DPS to facilitate best-in class planning and execution of transfer pricing policies, TP documentation, operationalization of TP, and TP defense and risk mitigation
• Provide advice and support to global tax, trade, and business partners as required, particularly in the areas of supply chain tax planning, IP planning, intercompany service arrangements and transfer pricing policies, including acquisitions and divestiture transactions
• Develop, implement, and maintain governance standards, as well as developing a process to ensure TP models are properly executed, maintained, and documented from a legal, operational, accounting, and tax compliance standpoint
• Manage the overall relationship with co-source providers on US Section 6662, master file, and local file TP documentation
• Educate Finance and business partners on the impacts of global tax law changes to TP policies, and support efforts with respect to tax policy developments, such as OECD developments, including TP implementation and impact modeling
• Assist in developing and executing strategies across the full range of global dispute resolution activities, including audits, MAPs, APAs, rulings, and risk-management insight in planning and implementation. Effectively deploy and supervise external advisors
• Create a globally applicable strategic approach to audits, particularly with respect to transfer pricing. This will involve crafting and implementing a best-in-class audit approach and coordination system, including a globally consistent approach to achieving tax certainty through the use of administrative, treaty-based, and courtbased resolution mechanisms, tax rulings, prefiling agreements, etc.
• Effectively coordinate between tax and the business, involving outside advisors and co-sourcing partners as appropriate, to respond to government requests for information, site visits, interviews, etc. The ability to see the big picture is key, as is the ability to craft strategic written responses and persuasive advocacy.
• Support valuations in DPS
• Responsible for the intercompany contractual framework for DPS
• Where appropriate, develop best-in-class approaches to recurring inquiries and issues
• Identify, assess, and mitigate potential planning hazards based on transfer pricing and disputes experience.

Qualifications

• A minimum of a bachelor’s degree is required, preferably in Accounting, Finance or Economics
• A minimum of 10 years of tax/business experience, including 5 years of transfer pricing and disputes experience, at an advisory firm or in-house experience at a major multinational corporation
• Experience defending multinationals at the various stages of audits and inquiries, including MAPs and APAs, witness preparation, and complex transfer pricing disputes
• Experience evaluating litigation hazards, particularly in the context of assessing the financial impact and reserves ramifications of ongoing audits and developments
• Excellent business partnering and communication skills – specifically the ability to effectively communicate highly technical matters in clear simple language to business partners around the world
• Strong influencing and collaboration skills, partnering with multiple stakeholders across the enterprise and external partners, including a network of legal and economic advisors across the globe
• Ability to develop talent and lead teams across the enterprise

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