The successful Taxation and Transfer Pricing Manager will manage and monitor global tax and transfer pricing compliance and advisory matters relating to Emirates, dnata and dnata World Travel, together with its subsidiaries (“the Group”). As Taxation and Transfer Pricing Manager, you will be primarily responsible (75 of the time) for the global transfer pricing position of the Emirates Group. You will be the central point of contact for the Group, acting as an internal transfer pricing specialist, working with internal and external stakeholders on various transfer pricing initiatives such as corporate cost recharges, transfer pricing related to commercial arrangements etc. You will also be responsible for (the management of) BEPS compliance related topics including but not limited to CbCR reporting, and preparation of Master and Local files.
The role is also expected to support on global tax compliance and advisory matters (25 of the time) including but not limited to corporate tax, tax structuring, OECD BEPS Pillar 2, audit management etc. You will need to be a clear communicator, work independently and proactively by partnering with the business and be able to formulate practical solutions that are in line with the Group’s tax policy, procedures and tax strategy.
In this role, you will:
- Provide tax and transfer pricing advice on a wide range of Group initiatives and projects. This includes, but is not limited to, the global implementation of transfer pricing strategies, compliance with OECD Pillar 2, international and local corporate income tax, tax structuring, mergers and acquisitions (M&A), group financing, business development opportunities (such as the introduction of new service offerings), internal group reorganisations, and other projects as they arise.
Specifically to Transfer Pricing:
- Ensure adherence to the Group’s transfer pricing policies and procedures across all jurisdictions, which may include conducting comparative benchmarking as necessary. Conduct functional and economic analysis to support transfer pricing strategies. Review related contracts to ensure alignment with both commercial objectives and transfer pricing regulations. Assist in negotiating transfer pricing arrangements with tax authorities, including securing agreements under advance pricing mechanisms where applicable. Review and update transfer pricing documentation annually, ensuring compliance with local regulations. Stay updated on changes in transfer pricing legislation across jurisdictions and assess their impact on the business.
- Oversee the successful management and implementation of specific transfer pricing projects. Take responsibility for the management and execution of the corporate cost recharge initiative, ensuring that relevant teams reconcile actual costs to original charges, maintain appropriate documentation and agreements, and manage invoicing and necessary adjustments throughout the year. Annually review the Group’s intra-group cost allocation methodology.
- Collaborate with key stakeholders to further develop and refine the Group’s transfer pricing strategy, ensuring ongoing compliance with evolving global tax regulations. Work alongside other finance departments and external specialists to maintain alignment with the latest regulatory changes and best practices. Conduct training and awareness sessions on importance and impact of transfer pricing on business operations.
- Partner with the Manager Taxation and Tax Managers globally (UK/India/Australia etc.) to support the implementation of other transfer pricing activities and monitor Group policies to ensure consistency with relevant tax laws and regulations (e.g., the arms length principle (ALP) and the Groups policies and internal legal framework. Manage the preparation and maintenance of the Group’s Master file and local files in the respective jurisdictions.
- Manage other transfer pricing / BEPS related projects and initiatives within the Group including CbCR reporting, CbCR notifications, preparation / maintenance of the TP master file and related local files, disclosure forms/ local transfer pricing return forms etc. You will also be responsible for other local and international compliance obligations such as FATCA etc., related to the Group. This will include data gathering activities, verification of data, preparation of reports and discussions with internal and external stakeholders on questions relating to data included in such reports as and when they arise.
- Manage external tax notices, audits and court cases initiated by external authorities, lead discussions with consultants independently, recommending courses of action/remediation through to conclusion.
Specifically to Tax Advisory:
- Review tax clauses in agreements and arrangements entered into by the Group, ultimately to minimise tax risks, costs and protect the interests of the Group. Advise and highlight implications of tax clauses to the business to help negotiate alternative tax clauses where appropriate.
- Preparation of tax reports to senior management highlighting key tax risks and updates, as and when they arise, in line with the Group’s Tax policy and procedures. Manage and respond to interim and year-end external tax audit queries related to Group tax matters.
