Transfer Pricing Manager

About the Role

The Transfer Pricing (TP) team at Dyson oversees all transfer pricing matters across our operations in over 30 countries. This includes compliance, managing disputes, handling mutual agreement procedures (MAP), negotiating advanced pricing agreements (APA), planning, conducting operational TP reviews, supporting year-end and statutory audits, advising on projects and new business arrangements, and routinely monitoring intercompany transactions.

Key Responsibilities

• Collaborate with local teams and advisors to comprehend business changes such as new markets or model adjustments to evaluate TP implications effectively.
• Support TP aspects across various business projects, coordinating with Group Tax, Treasury, and Customs departments to address correlated TP considerations.
• Assist with the implementation and upkeep of global transfer pricing policies and procedures.
• Stay abreast of transfer pricing regulations and guidelines, assessing their business impacts and escalating concerns timely.
• Review and ensure timely filing of transfer pricing documentation, returns, Country-by-Country Reporting (CbCR) notifications, and related declarations, including preparation in some countries.
• Conduct functional interviews with internal stakeholders to ascertain relevant functions, assets, and risks.
• Manage transfer pricing controversies by overseeing TP audits and working with advisors on MAP, ensuring compliance with group policies.
• Provide support for TP planning, operational TP, and APA negotiations.
• Identify and communicate transfer pricing risks promptly, assisting in the development of mitigation strategies.
• Analyze how TP policies affect financial performance and deliver timely TP data to internal teams.
• Support year-end TP processes, including analyzing intercompany transactions and proposing necessary adjustments.
• Establish and maintain intercompany agreements.
• Review local statutory accounts to ensure TP results align with expectations and recommend adjustments, coordinating with tax and customs teams as needed.
• Perform quarterly TP reviews to verify appropriate remuneration of local entities, collaborating with finance and corporate tax teams.
• Monitor intercompany transactions, including financing, to maintain correct TP positions and resolve issues swiftly.
• Evaluate and recommend enhancements to TP processes, exploring automation and AI opportunities to increase efficiency and compliance.
• Offer ad-hoc TP support to stakeholders and tax/customs teams.
• Develop strong relationships with advisors, internal departments such as finance, legal, treasury, other tax offices, and shared service centers to achieve TP objectives.
• Provide guidance and assistance to fellow TP team members.

Qualifications & Experience

• Minimum of 8 years’ experience in public accounting and/or corporate settings, preferably with exposure to Big 4 firms and in-house roles in the FMCG sector.
• Experience handling transfer pricing matters across multiple jurisdictions.
• Knowledge and experience with APAs, MAPs, managing controversies, and familiarity with transactional profit split methods.
• Strong grasp of OECD Transfer Pricing Guidelines; knowledge of Amount B is advantageous.
• Proven ability to juggle multiple tasks, meet deadlines, and implement practical solutions.
• Analytical mindset with a capacity to adopt comprehensive business and commercial perspectives.
• Strong motivation to learn and perform ground-level work.
• Interest in economic and business concepts combined with understanding of international TP laws and regulations.
• Comfortable using technology platforms such as SAP, OneStream, and Alteryx.
• Collaborative team player committed to sharing knowledge and supporting peers.

Additional Information

Educational preference for candidates holding a Bachelor's degree in Accounting, Finance, or related Business/Economics fields. Professional qualifications like CPA and advanced taxation certificates are advantageous.

Dyson promotes diversity and is an equal opportunity employer, valuing varied perspectives and backgrounds without discrimination based on race, ethnicity, religion, gender identity, sexual orientation, age, disability, veteran status, or other protected categories.