Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy

Aptiv; Schaffhausen; Vor Ort; CHF 150.000 - 230.000; Vollzeit

Zusammenfassung

Aptiv is seeking a Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy to guide the Company’s tax strategy across EMEA. You will lead cross‑jurisdictional planning, TP governance and controversy efforts, coordinating with Treasury, Finance and Legal to ensure defensible positions and compliant documentation.

You will develop technically robust, commercially practical tax solutions, lead APAs and MAPs, and oversee complex cross‑border projects while partnering with senior

Qualifikationen

• 10+ years of international tax, transfer pricing, planning and controversy experience.
• Experience with APAs, MAPs, audits and dispute resolution.
• Proven ability to lead multi-jurisdictional tax projects and engage senior stakeholders.

Aufgaben

• Lead EMEA tax planning initiatives and governance for multiple jurisdictions.
• Oversee transfer pricing policies, documentation and defense strategies across entities.
• Manage APAs, MAPs, audits, controversy matters and dispute resolution across regions.
• Lead and coordinate tax governance with Treasury, Finance and Legal; engage authorities and advisors.

Kenntnisse

International tax

Transfer pricing

Tax planning

Tax controversy

Cross-border tax

Jobbeschreibung

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.

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

• 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

Experience

• 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.