To work on all matters relating to the transfer pricing affairs of the Group, taking responsibility for transfer pricing methodologies, documentation, agreements, calculations and process, invoicing, document retention, etc. Essentially this is a wide ranging transfer pricing role, and the candidate will be proactively driving the transfer pricing agenda across all legal entities and business lines in the Group.
Specific responsibilities include:
Methodologies:
? Undertaking detailed and comprehensive functional, organisational and economic analyses on business lines and legal entities
? With the support of the International Head of Tax, developing appropriate transfer pricing methodologies in relation to both revenues and costs, taking into account OECD thinking and local rules and practice
? Undertaking, where necessary and with the support of external advisors, benchmarking studies
? Developing sustainable tax return filing positions in relation to transfer pricing and permanent establishment issues
Documentation:
? Preparing comprehensive transfer pricing documentation for all transfer pricing arrangements within the Group
? Maintaining and updating documentation in line with local requirements for the purposes of tax audit
? Preparing documentation in relation to all aspect of the Finance process impacting on any of the transfer pricing arrangements in place (i.e. assumptions, criticalities, cost / revenue allocation models, etc)
Agreements
? Working with Legal and local management, implementing transfer pricing agreements for all transfer pricing arrangements within the Group
Calculations and process
? Working with Finance to ensure the correct implementation and calculation of transfer pricing based on the transfer pricing methodologies adopted
? Back testing and analysis of transfer pricing for control and management reporting purposes
? Development of systems (working with Finance, business areas, etc) to produce numbers (e.g. for sales credits) compatible with the transfer pricing methodologies adopted
Invoicing
? Working with Finance to ensure appropriate invoicing arrangements
? Ensuring the correct application of indirect taxes to transfer pricing payments
Others
? Assisting locations with transfer pricing audits
? Ensuring that systems and processes are in place to maintain all documentation and numerical audit trail for audit purposes
? Working with the International Head of Tax to analyse tax risk in relation to transfer pricing and, where necessary, to provision and report to management on such risk
? Ensuring full communication with all stakeholders on transfer pricing matters
? Working on new product proposals and business initiatives to develop appropriate transfer pricing arrangements
Candidate sought:
Given the nature and scope of the role, the candidate should have a strong background in financial services transfer pricing and ideally be working (or have worked) in the in-house tax department of a bank or similar institution. The candidate should be appropriately qualified (ATII / CTA / HMRC trained). Strong numeracy, accountancy and computer skills will be required.
In view of the likely need to interact daily with different areas of the bank, the candidate should possess excellent interpersonal skills and an ability to develop good working relationships. The candidate should be a strong personality and must be capable of functioning both autonomously - working largely under their own supervision - and within a team. Good organisational skills are therefore also essential.
This role is very hands-on and will require a significant amount of analytical work and interaction with Finance in relation to process and the detailed implementation of transfer pricing arrangements. Candidates who have worked in transfer pricing roles in a more advisory / managerial capacity may not have the practical experience required, and this will be tested in the interview process.
This is a stand-alone role, although the candidate will have the support of members of the tax department as well as staff in other areas impacted by transfer pricing (e.g Finance). Without the direct support of a transfer pricing team, the successful candidate will find the workload challenging, but the role will be varied and highly rewarding.
The role may involve some travel within EMEA.
Pure Recruitment Group Limited acts as an employment agency for permanent roles and an employment business for temporary roles. Pure Recruitment Group Limited aims to promote diversity and equal opportunity through its work - we monitor and evaluate our performance on a regular basis.
Please note our advertisements use PQE levels purely as a guide to the minimum level of experience that we anticipate will be needed to fulfil the position. However, we are happy to consider applications from all candidates who are able to demonstrate the skills necessary to fulfil the role and they will be considered on an equal basis.
Pure Taxation was established in 1999 as part of the Pure Recruitment Group. Rather than imitate existing providers of tax recruitment consultancy, we sought to create a new methodology based on quality, relationships and integrity. Since then, Pure Taxation has become market leader in the UK because of our approach to recruitment and the excellence of our experienced consultants, making us a profitable business every year since inception.
Our current team comprises of 16 specialist consultants in London and Hong Kong focusing on permanent tax recruitment in the UK, EMEA and Asia Pacific regions, three specialists in interim tax recruitment and four dedicated support and research staff, making us the largest dedicated tax recruiter in the UK.
