Director, Global Transfer Pricing

BeOne Medicines Ltd.; San Mateo (CA); Sur place; USD 180 000 - 320 000; Plein temps

Résumé du poste

BeOne Medicines Ltd. in San Mateo, California is seeking a Director, Global Transfer Pricing to lead strategy and governance for intercompany pricing across jurisdictions.

You will partner with Finance, Legal, Treasury, Supply Chain, Commercial, Manufacturing, R&D, and Business Development to align value creation with IP ownership and the company operating model. This role will drive TP policy implementation, performance reporting, and the automation of TP processes, including Master/Local Files

Qualifications

• 12+ years of transfer pricing experience in a multinational corporation and/or Big Four advisory environment.
• Deep expertise in OECD Transfer Pricing Guidelines, BEPS initiatives, benchmarking studies and global documentation requirements.
• Significant experience with intellectual property, licensing, manufacturing, distribution, services, and financing transactions.
• Extensive experience using SAP (including S/4HANA environments) to support transfer pricing execution and reporting.
• Demonstrated experience automating transfer pricing calculations and intercompany entries.
• Proven experience negotiating and managing APAs and supporting MAP proceedings.
• Experience defending transfer pricing positions in audits across multiple jurisdictions.

Responsabilités

• Develop and maintain the Company's global transfer pricing framework, policies, and governance standards.
• Ensure alignment between transfer pricing outcomes and business operations, value creation, intellectual property ownership, and economic substance.
• Oversee implementation and execution of global transfer pricing policies across all jurisdictions.
• Lead preparation of Master Files, Local Files, Country-by-Country Reporting support, benchmarking studies, and audit-ready documentation.
• Provide transfer pricing leadership for acquisitions, licensing arrangements, collaborations, joint ventures, and other strategic transactions.
• Lead transfer pricing audit defense and controversy management activities globally.
• Drive automation, process enhancement, and digital transformation initiatives related to transfer pricing operations.
• Lead APA strategy, negotiations, implementation and compliance activities.
• Manage MAP and competent authority proceedings where appropriate.

Formation

Bachelor’s degree in Accounting, Finance, Economics, or related field

Advanced degree (Master's in Taxation, Economics, Accounting, or MBA)

Outils

SAP (S/4HANA)

Description du poste

General Description

The Director, Global Transfer Pricing is a strategic leadership role within the Global Tax organization responsible for developing, implementing, and governing the Company's global transfer pricing strategy. This position provides leadership over transfer pricing policy, value chain alignment, intercompany transactions, tax authority controversy management, and operational transfer pricing governance. The Director partners closely with Finance, Legal, Treasury, Supply Chain, Commercial, Manufacturing, R&D, and Business Development teams to ensure transfer pricing outcomes appropriately reflect the Company's global operating model, intellectual property ownership structure, and value creation activities.

Essential Functions of the Job

• Develop and maintain the Company's global transfer pricing framework, policies, and governance standards.
• Ensure alignment between transfer pricing outcomes and business operations, value creation, intellectual property ownership, and economic substance.
• Oversee implementation and execution of global transfer pricing policies across all jurisdictions.
• Lead preparation of Master Files, Local Files, Country-by-Country Reporting support, benchmarking studies, and audit-ready documentation.
• Provide transfer pricing leadership for acquisitions, licensing arrangements, collaborations, joint ventures, and other strategic transactions.
• Lead transfer pricing audit defense and controversy management activities globally.
• Drive automation, process enhancement, and digital transformation initiatives related to transfer pricing operations.
• Lead APA strategy, negotiations, implementation and compliance activities.
• Manage MAP and competent authority proceedings where appropriate.

Technology & Transformation

• Drive SAP-enabled transfer pricing process improvements.
• Lead tax technology and automation initiatives.
• Leverage AI and analytics to improve controls and operational efficiency.

Leadership & Stakeholder Management

• Ability to work on a matrix environment and supervise a broad external advisor network.
• Partner with Treasury, Legal, Supply Chain, R&D, Manufacturing and Commercial teams.

Qualifications

• 12+ years of transfer pricing experience in a multinational corporation and/or Big Four advisory environment.
• Bachelor’s degree in Accounting, Finance, Economics, or related field required. Advanced degree (Master's in Taxation, Economics, Accounting, or MBA) preferred.
• Deep expertise in OECD Transfer Pricing Guidelines, BEPS initiatives, benchmarking studies and global documentation requirements.
• Significant experience with intellectual property, licensing, manufacturing, distribution, services, and financing transactions.
• Extensive experience using SAP (including S/4HANA environments) to support transfer pricing execution and reporting.
• Demonstrated experience automating transfer pricing calculations and intercompany entries.
• Proven experience negotiating and managing APAs and supporting MAP proceedings.
• Experience defending transfer pricing positions in audits across multiple jurisdictions.

Preferred Qualifications

• Pharmaceutical, biotechnology or life sciences industry experience.
• Experience leading global transfer pricing transformations.
• Experience supporting Pillar Two implementation.
• Experience managing global transfer pricing models.

Critical Leadership Competencies

• Strategic Transfer Pricing Leadership
• Executive Presence and Communication
• Transfer Pricing Audit and Controversy Management
• Technology and Automation Leadership
• Cross-Functional Collaboration
• Risk Management and Governance

All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability or protected veteran status.