Director of Transfer Pricing
Job Description
Primary Purpose:
The Director Transfer Pricing, under direction of the VP Tax and consistent with company policy and generally accepted accounting principles, is responsible for directing and developing strategies and supporting the business operations to minimize worldwide income tax in collaboration with the Global tax team, provides general advice and planning services to the business where cross border transactions are present, directs the compliance with transfer pricing regulations across the world.
Primary Duties:
- Directs the execution of, modeling of and identification of various tax planning strategies that involve cross border transactions such as licensing of IP and/or cross border charges for services (i.e. management, engineering, etc) to minimize the income tax burden of the Company.
- Directs and overseas the global management and inter company pricing and valuation of the Company's intellectual property to ensure compliance with various jurisdiction transfer pricing and valuation laws as well as identification of tax strategies to minimize the overall global tax for the Company.
- Directs and leads preparation of valuations and interest rate setting on inter company loans that are required for various tax-initiated projects including transfers of products, functions, risks, businesses, etc. in cooperation with Tax Counsel.
- Establish, maintain and communicate Inter company transaction policies to ensure global operations are aware of them and that we update them to reflect any changes in the operations.
- Proactively works closely with business leadership in analyzing the tax effect of current or proposed transactions, business realignments, etc. including cross border transactions, acquisitions, and divestitures and facilitates the preparation of intercompany legal agreements that are required to support and facilitate the ever changing business transactions between the Company's legal entities.
- Work closely with external and internal legal counsel to ensure proper inter company agreements are maintained and reflect the current business practices of the Company.
- Represent the Company with respect to Advanced Pricing Agreements and other Competent Authority matters with various tax authorities to ensure we have presented the proper facts and documentation to support our inter company policies.
- Directs the completion of all contemporaneous documentation and analysis required to support intercompany cross border transactions across the Company including, but not limited to, intellectual property rights, product sales, and services.
- Directs the identification and implementation of ongoing process improvements within the worldwide transfer pricing compliance area to improve efficiency, accuracy and the documentation of positions, including coordination with various members of the Tax department and finance personnel within the business and accounting.
- Contributes toward the successful completion of income tax audits that include transfer pricing issues, inclusive of audits, competent authority filing support, etc.
- Work closely with JCI on providing the proper support as required under the SAPA and ensure responses to government authorities are consistent with the Company's position and that the Company is properly protected and indemnified by JCI as necessary.
- Provides support in identifying, documenting, and monitoring any uncertain tax positions under FIN48 in the transfer pricing area.
- Contributes toward the completion and review of the quarterly effective rate and any estimated US income tax payments with respect to the transfer pricing aspects of these items.
- Develop through supervision, training, and exposure to skills development work experiences.
- Respond to tax authority information requests with respect to transfer pricing matters
- Assist with various additional projects as directed by the VP Tax.
Job Specifications:
- Minimum of 12 years of experience in progressively responsible positions in transfer pricing or tax planning in industry. International transfer pricing experience is a plus. Industry experience with a large multinational company is a plus.
- Bachelor's degree in Economics, Finance, Business or Accounting
- Advanced degree in tax, law, economics, or related field preferred.
- Proven ability to write clearly and effectively.
- Demonstrated skill in interpreting complex data that may come from a variety of sources in a multiple formats.
- Experience managing cross functional teams and projects at various levels
- Solid project management skills.
- Talent for independently managing an ever-shifting work load and priorities while working in a team with various members of the tax department and/or business units.
- Ability to travel.
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Who we are:
Clarios is the creator behind the world's most recognizable car battery brands. We are the car battery found in most new vehicles including leading brands such as Ford, General Motors, Toyota, Honda, and Nissan. Our 16,000 employees develop, manufacture, and distribute batteries for virtually every type of vehicle. We recover, recycle, and reuse up to 99% of our battery materials, leading sustainability practices in our industry. Clarios, formerly Johnson Controls Battery Group, is currently a Brookfield portfolio company. Learn more about us at www.clarios.com.
We recognize that people come with a wealth of experience and talent beyond just the technical requirements of a job. If your experience is close to what you see listed here, please apply. Diversity of experience and skills combined with passion is key to challenging the status quo. Therefore, we encourage people from all backgrounds to apply to our positions. Please let us know if you require accommodations during the interview process by emailing [email protected]. We are an Equal Opportunity Employer and value diversity in our teams in terms of work experience, area of expertise, gender, ethnicity, and all other characteristics protected by laws in the countries where we operate. For more information on our commitment to sustainability, diversity, and equal opportunity, please read our latest report. We want you to know your rights because EEO is the law.
To all recruitment agencies: Clarios does not accept unsolicited agency resumes/CVs. Please do not forward resumes/CVs to our careers email addresses, Clarios employees or any other company location. Clarios is not responsible for any fees related to unsolicited resumes/CVs.
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Directs the execution of Jobs
modeling of and identification of various tax planning strategies Jobs
Directs and oversees the global management and inter company pricing and valuation of the Company's intellectual property Jobs
Establishes Jobs
maintains and communicates Inter company transaction policies Jobs
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Jobs in Milwaukee, WI
Date Posted
07/29/2023
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Subjectivity Score: 0.9
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