Senior Transfer Pricing Manager

Key Responsibilities:

•   Collaborate with local teams and advisors to gain insights into the business and any evolving changes, ensuring that transfer pricing (TP) implications are adequately addressed (e.g., modifications in business model, expansion into new markets, etc.).

•   Lead or assist in various business initiatives and projects to guarantee the effective implementation of TP solutions. Coordinate with other departments within the Group Tax, Treasury, and Customs functions to assess related TP matters more comprehensively.

•   Contribute to the creation, execution, and upkeep of global transfer pricing policies and procedures.

•   Stay informed on updates in TP law and practice, evaluating their implications for the business.

•   Examine transfer pricing documentation, declarations, Country-by-Country Reporting (CbCR) notifications, Advance Pricing Agreements (APRs), and other compliance-related forms prepared by advisors, ensuring timely filing by statutory deadlines. Some documentation may be prepared internally.

•   Conduct functional interviews with internal stakeholders to gain a clear understanding of the relevant Functions, Assets, and Risks (FAR).

•   Oversee TP controversy management, including audits and collaboration with advisors on mutual agreement procedures (MAP). This includes coordinating with local Dyson entities and advisors to ensure local TP audits are managed effectively and in accordance with group policies.

•   Engage in TP planning, including operational transfer pricing and leading automation processes alongside advisors on APAs.

•   Identify potential transfer pricing risks and devise strategies to mitigate them.

•   Analyze the effects of transfer pricing policies on financial outcomes and provide precise and timely TP data to relevant internal stakeholders.

•   Assist with year-end TP processes, including the analysis and review of intercompany transfer pricing results, determining and proposing TP adjustments, and analyzing uncertain tax provisions (UTP) related to TP issues.

•   Develop and implement intercompany agreements.

•   Review local statutory accounts to ensure that appropriate TP results are achieved and suggest TP adjustments as necessary. Collaborate with advisors, the corporate tax team, and the customs team to determine the best approach for implementing TP adjustments.

•   Conduct quarterly TP reviews to ensure that local entities are compensated appropriately. This involves working with local finance and corporate tax teams to understand and validate forecasts.

•   Monitor inter-company transactions, including financing transactions, to ensure suitable TP positions are maintained and promptly identify and resolve issues.

•   Review existing TP processes and implement enhancements and efficiencies where applicable.

•   Provide ad-hoc TP assistance to internal stakeholders and/or corporate tax/customs teams as needed.

•   Cultivate and manage relationships with Dyson's advisors, internal stakeholders (finance, legal, treasury, other tax and customs teams), and shared service teams to execute the aforementioned responsibilities.

•   Offer guidance and support to other team members.

Qualifications:

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

•   Over 10 years of experience in public accounting and/or corporate settings. Experience in both Big 4 firms and in-house roles (particularly in FMCG) is a plus.

•   Demonstrated experience addressing TP issues across multiple jurisdictions.

•   Familiarity with APAs, MAPs, controversy management, and the application of transactional profit split methods.

•   Strong comprehension of OECD TP guidelines, with some knowledge of Amount B being a plus.

•   Ability to manage multiple tasks, meet deadlines, and implement practical solutions.

•   Skilled at connecting diverse elements and maintaining a broad business and commercial perspective.

•   Eager learner with a willingness to perform foundational work.

•   Strong interest in and capability to understand economic/business concepts and TP laws/regulations in different countries.

•   Proficient with technology (e.g., SAP, OneStream, Alteryx).

•   Collaborative team player willing to assist, share knowledge, and mentor others.