Transfer Pricing Assistant VP
Purpose of Job:
- To provide Transfer Pricing ("TP") advice and support to internal stakeholders in relation to the project in establishing a universal bank in Germany and the UK ("Project").
- To redesign and implement the new TP procedures and processes relating to Intra-group Transaction (services and revenue sharing) flows that aligned with the universal bank model.
- To document the new Intra-group Transactions i) in an OECD prescribed format to meet the local TP documentation requirements and ii) in process documents for implementation and control purposes.
- The establishment of a universal banking platform across EMEA is one of the core strategic goals over the coming years. The ultimate aim is to create a universal banking platform, delivering a full suite of corporate finance solutions to our customers across the region. The universal banking model will also manage the new EU law which requires non-EU banking groups to establish an EU intermediate parent undertaking ("IPU").
- The Project is supporting the above objectives through integration in the UK and EU AG and CM Frankfurt in Germany.
Facts / Scale:
- The role is to assist the Project team and EMEA Tax in developing appropriate TP models and processes that are properly implemented in complying with the arm's length principles and adequately documented in meeting the local TP rules.
- The role holder will be working closely with Project team, EMEA business, finance and tax teams, PD Planning teams
Accountabilities & Responsibilities:
- Assist in managing the day-to-day activities / requirements of the Project in providing TP technical advice and support to the Project team while ensuring TP approaches adopted in the UK and Germany are consistent with the EMEA TP policy
- Conduct functional interviews / analyses with the departments in understanding the Intra-group Transactions in scope and developing the economic analysis and their applications.
- Assist in managing the service fee calculations for intra-group services and the associated processes ensuring that they are consistent with the group TP policy and contractual agreements.
- Assist in setting up and implementing of any new TP models / calculations developed for universal banking model e.g., identify the relevant type of data, sources to enable TP calculations.
- Document the new Intra-group Transactions in an OECD prescribed format to meet the local TP documentation requirements, including the TP processes and procedures.
Knowledge, Skills, Experience & Qualifications:
- Solid technical expertise and understanding of the OECD and local transfer pricing laws, tax controversy and regulations, and related corporate tax matters.
- Qualified transfer pricing professional with experience gained from Big 4, or preferably combined with in-house tax experience in the financial sector.
- Strong project management skills and ability to manage and prioritise multiple projects.
- Ability to work as a member of a team and contribute to collective decision making is essential.