The Transfer Pricing (“TP”) Team manages all transfer pricing aspects of the Dyson Group, with presence in more than 30 countries globally. This includes (but is not limited to) TP compliance, controversy management, mutual agreement procedure (“MAP”) and advanced pricing agreement (“APA”) application and negotiation, TP planning, operational TP, TP model review, supporting with TP aspects of year end and statutory audit processes, supporting with TP aspects of projects and new business arrangements, TP advisory and regular monitoring of intercompany transactions.
The person in the role will work with internal finance teams, other tax teams (e.g. Corporate Tax, Customs, Indirect Tax) and external tax advisors to ensure timely and accurate compliance. The person will also be involved in providing support to the business – this involves identifying all TP implications of a given business initiative, arrangement or change, adequately considering commercially viable mitigating strategies and bringing these up for discussion with the Head of Transfer Pricing / Senior Transfer Pricing Manager, and cogently communicating aligned responses to all relevant stakeholders. The person will also be involved in supporting the Head of Transfer Pricing / Senior Transfer Pricing Manager with interactions with tax authorities (e.g. in controversy, APA, MAP etc.) and working with various stakeholders to ensure TP positions are actively monitored and rectifications made in a timely manner.
This role will be based in Singapore.
Principal responsibilities:
Work with the local teams and advisors to understand the business and any changes to ensure TP implications are appropriately considered (e.g. changes in business model, entering into new locations, etc.).
Support on TP elements of various business initiatives and projects. Work with other teams within the Group Tax, Treasury and Customs function to ensure that any related TP issues are considered more holistically.
Support the implementation and maintenance of global transfer pricing policies and procedures.
Keep updated on developments in TP law/practice, assess their impact on the business and flag issues for resolution on a timely basis.
Review transfer pricing documentation, transfer pricing returns/declarations, CbCR notification, ACRs and any other transfer pricing related compliance returns and forms prepared by advisors and ensure they are filed by the required statutory deadline. Preparation of the same in select countries that do not have external advisor support.
Provide support on functional interviews with internal stakeholders to understand the relevant FAR.
Manage TP controversy including managing TP audits and working with advisors on mutual agreement procedure (“MAP”). This also includes working with the local Dyson entities and advisors to ensure that local TP audits are managed effectively and in-line with group policies.
Provide support on TP planning (including operational TP) and APAs.
Identify potential transfer pricing risks, flag these out on a timely basis and provide support in developing solutions to mitigate these risks.
Analyse the impact of transfer pricing policies on financial performance and provide accurate and timely transfer pricing data to other internal stakeholders.
Support year end TP processes including analysing and reviewing intercompany transfer pricing results, working out and proposing TP adjustments.
Develop and implement intercompany agreements.
Review local statutory accounts to ensure appropriate TP results are achieved and proposing TP adjustments where required. Liaise with advisors/Corporate tax team/Customs team to understand how best to put through TP adjustments.
Perform quarterly TP reviews to ensure local entities are appropriately remunerated. This includes working with the local finance and/or corporate tax teams to understand and verify forecasts.
Monitor inter-company transactions (including inter-company financing transactions) to ensure appropriate TP positions are taken and identify and rectify issues on a timely basis.
Review existing TP processes and suggest improvements and efficiencies where appropriate. Explore the use of artificial intelligence and/or automation to further process improvements and/or meet new TP compliance requirements.
Provide ad-hoc TP support to internal stakeholders and/or corporate tax/customs teams as required.
Build and manage relationships with Dyson’s advisors, internal stakeholders (finance, legal, treasury, other tax and customs teams) and shared service teams to perform the abovementioned activities.
Provide support to other members of the TP team.
Requirements:
Bachelor’s Degree in Accounting, Finance, or Business/Economics-related discipline preferred. CPA and/or advanced taxation certification is a plus.
8+ years’ experience in public accounting and/or corporate environment. Having both Big 4 and in-house experience (especially in FMCG) is a plus.
Prior experience dealing with TP issues in multiple jurisdictions.
Prior experience with APAs, MAPs, controversy management and familiar with application of transactional profit split.
Strong understanding of OECD TP guidelines. Some familiarity with Amount B is a plus.
Ability to multi-task, handle deadlines and implement practical solutions.
Ability to connect the dots and adopt a big picture business and commercial view.
Keen learner and willingness to do the ground work.
Keen interest in and ability to grasp economic/business concepts and TP laws/regulations of other countries.
Comfortable with technology (e.g. SAP, OneStream, Alteryx).
Team player who is willing to help, share and guide others.
Dyson is an equal opportunity employer. We know that great minds don’t think alike, and it takes all kinds of minds to make our technology so unique. We welcome applications from all backgrounds and employment decisions are made without regard to race, colour, religion, national or ethnic origin, sex, sexual orientation, gender identity or expression, age, disability, protected veteran status or other any other dimension of diversity.
