Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy

Aptiv Manufacturing Management Services GmbH; Schaffhausen; Presencial; CHF 200 000 - 260 000; Tempo integral

Vantagens oferecidas por esta oferta de emprego

Work location in Schaffhausen

Resumo da oferta

Aptiv Manufacturing Management Services GmbH in Schaffhausen is seeking a Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy to lead tax strategy across EMEA, incl. transfer pricing governance, APAs, MAPs and dispute resolution.

You will collaborate with Tax, Treasury, Finance and Legal to develop defensible positions, manage cross-border financing structures and ensure compliant documentation.

Qualificações

• 10+ years of international tax, transfer pricing, tax planning and controversy within multinational settings.
• Experience managing cross-border matters across multiple jurisdictions.
• Experience with APAs, MAPs, tax audits, controversy and dispute resolution.
• Strong knowledge of transfer pricing governance and OECD guidelines.
• Experience with cross-border financing and treasury-related tax issues.

Responsabilidades

• Lead EMEA tax planning initiatives for assigned jurisdictions.
• Oversee transfer pricing governance and intercompany documentation.
• Coordinate APAs and MAPs negotiations with tax authorities.
• Manage tax controversy programs including audits, appeals and dispute resolution.
• Collaborate with Tax, Treasury, Finance and Legal to ensure governance and defensible positions.

Conhecimentos

Analytical skills

Communication

Problem solving

Leadership

Fluent English

Formação académica

Master's degree in Tax/Finance/Law

Advanced transfer pricing qualifications

Descrição da oferta de emprego

Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy

Aptiv Manufacturing Management Services GmbH Vacant since : 10.09.2026 Number of jobs : 1 8200 Schaffhausen (SH) 100% Immediately Permanent

Aptiv is seeking a Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy to support the Company's tax strategy across EMEA. The role will be responsible for developing and implementing technically robust, commercially practical and defensible tax solutions, while managing transfer pricing, tax planning and tax controversy matters across assigned jurisdictions.

The successful candidate will lead complex international tax projects including cross-border financing arrangements, transfer pricing governance, advance pricing agreements (APAs), mutual agreement procedures (MAPs), tax audits, controversy matters and dispute resolution. The role requires close collaboration with Tax, Treasury, Finance, Legal, business stakeholders, tax authorities and external advisors.

Position & Responsibilities

Tax & Treasury Liaison

Serve as the 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.Support the implementation of tax-efficient and commercially practical financing structures.Partner with Finance, Treasury and Legal to ensure appropriate tax governance and documentation is maintained.

Tax Planning & International Tax

Lead EMEA tax planning initiatives for assigned jurisdictions.Identify and evaluate tax planning opportunities arising from business operations, restructurings and financing activities.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 international tax issues including cross-border transactions, withholding taxes and treaty application.Monitor developments in OECD guidance, EU tax developments and local legislation.

Transfer Pricing

Lead transfer pricing governance for financing, treasury, leasing, intellectual property and other intercompany transactions.Oversee development and maintenance of transfer pricing policies in accordance with OECD Guidelines and local requirements.Coordinate transfer pricing documentation and defense strategies globally in collaboration with the Transfer Pricing team.Support implementation of transfer pricing policies across business units and jurisdictions.Ensure appropriate governance and controls are maintained over intercompany arrangements.

APAs & MAPs

Lead and manage Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).Develop technical positions and submissions for tax authorities.Coordinate internal stakeholders and external advisors throughout negotiations and dispute resolution processes.Support resolution of double taxation and cross-border transfer pricing disputes.

Tax Controversy & Advocacy

Lead the EMEA Tax Controversy Program for assigned jurisdictions.Manage tax inquiries, audits, appeals, litigation and dispute resolution matters.Develop audit defense strategies and supporting documentation.Prepare technical memoranda and supporting evidence to defend material tax positions.Coordinate responses with tax authorities and external advisors.Maintain controversy assessments and reporting processes for management and compliance purposes.Lead complex controversy matters involving transfer pricing, international tax and financing structures.Assess legislation and develop technical and legal arguments supporting the Company's positions, including matters involving EU law and OECD principles.Leadership & Stakeholder Management

Leadership & Stakeholder Management

Lead complex multi-jurisdictional projects involving Tax, Treasury, Finance, Legal and business leadership.Build and maintain strong relationships with tax authorities, external advisors and internal stakeholders.Present complex technical matters clearly and effectively to senior management.Promote strong tax governance, documentation and risk management practices across the region.

Requirements

10+ years of relevant experience in international tax, transfer pricing, tax planning and tax controversy within a multinational corporation, Big Four accounting firm and/or law firm.Significant experience managing complex cross-border tax matters across multiple jurisdictions.Experience with APAs, MAPs, tax audits, controversy matters and dispute resolution.Strong experience in transfer pricing, OECD Guidelines and transfer pricing governance.Experience with cross-border financing structures, treasury-related tax issues, withholding taxes and treaty interpretation.Experience working with tax authorities and managing external advisors.Experience supporting multinational operations across EMEA.

Education & Professional Qualifications

Degree in Law, Tax, Accounting, Finance, Business or a related discipline.Master's degree or advanced professional qualification in Tax, International Tax or related field preferred.Advanced transfer pricing qualifications and/or demonstrated expertise in OECD transfer pricing principles highly desirable.Strong technical knowledge of international tax, transfer pricing, OECD guidelines and tax controversy practice.

Skills & Competencies

Excellent analytical, advocacy and problem-solving skills.Strong written and verbal communication skills.Ability to develop technically robust and commercially practical solutions.Proven ability to lead projects and influence stakeholders across multiple functions and jurisdictions.Strong relationship management skills with internal and external stakeholders.Fluent English required.German language capability is an advantage#LI-PT2

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Aptiv is an equal employment opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, national origin, sex, gender identity, sexual orientation, disability status, protected veteran status or any other characteristic protected by law.

• Work location 8200 Schaffhausen (SH)
• Additional information on the place of work Spitalstrasse 5, 8200 Schaffhausen, Switzerland
• Workload 100%
• Employment start Immediately
• Employment duration Permanent
• Qualification skilled
• Work experience More than 3 years
• Education Master’s degree from a university or equivalent
• English Orally : Very good knowledge Written : Very good knowledge
• By online Online form