EMEA Tax Strategy Lead: Planning, TP & Controversy

Aptiv PLC; Schaffhausen; Hybrid; CHF 180,000 - 240,000; Full time

Job summary

Aptiv PLC in Switzerland seeks a Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy to lead tax strategy across the region. You will manage transfer pricing, tax planning and controversy initiatives, coordinating with Finance, Legal and external advisors.

Responsibilities include leading APAs/MAPs, developing audit-defensible positions, and guiding cross-border financing structures in line with OECD guidelines. Strong leadership and stakeholder management are required.

Qualifications

• 10+ years of international tax, transfer pricing, and controversy experience.
• Experience with APAs, MAPs, and cross-border disputes.
• Experience with OECD guidelines and transfer pricing governance.
• Ability to lead multi-jurisdictional projects.
• Strong collaboration with internal and external stakeholders.

Responsibilities

• Serve as primary tax liaison to Treasury on funding, liquidity, capital structure, intercompany financing, leasing and hedging transactions.
• Provide tax and transfer pricing guidance on financing arrangements and treasury initiatives.
• Advise on withholding tax, treaty interpretation, beneficial ownership and other cross-border financing matters.
• Lead EMEA tax planning initiatives for assigned jurisdictions.
• Develop technically supportable and audit-defensible positions on international tax matters.
• Present tax planning opportunities, risks and recommendations to senior tax leadership.
• Support legal entity rationalizations, restructuring projects and operating model changes.
• Provide technical advice on cross-border transactions and treaty applications.
• Monitor OECD and EU tax developments and local legislation.

Skills

Transfer pricing

APAs & MAPs

Tax planning

Cross-border financing

OECD guidelines

Stakeholder management

Leadership

Education

Law, Tax, Accounting, Finance or related discipline

Master's degree or advanced professional qualification in Tax

OECD transfer pricing qualifications

Job description

Aptiv PLC in Switzerland seeks a Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy to lead tax strategy across the region. You will manage transfer pricing, tax planning and controversy initiatives, coordinating with Finance, Legal and external advisors.

Responsibilities include leading APAs/MAPs, developing audit-defensible positions, and guiding cross-border financing structures in line with OECD guidelines. Strong leadership and stakeholder management are required.