Senior Manager Transfer Pricing (NL)
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In a nutshell
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Are you interested in becoming part of ASML Tax, a department in which you will face demanding challenges and enjoy the freedom to operate and do what is good for the company? You will focus on Dutch and partly on global pricing matters which will give you the opportunity to work with a broad range of stakeholders locally and internationally.
This position will report to the Global Head of Transfer Pricing based in the Netherlands, focusing on Netherlands transfer pricing matters and partially global transfer pricing matters given ASML’s worldwide HQ location in the Netherlands. The position will be one of four(senior) tax managers, next to the Global Head of Transfer Pricing, making up the Global Transfer Pricing Team. The job will require internal interfaces with all ASML departments and Senior Management and external interfaces with outside counsel and consultants, tax authorities and other (governmental) institutions.
- Support and execute the Global Tax Strategy and underlying Global Transfer Pricing strategy of the ASML group of companies.
- Contribute and ensure adherence to the regional policies for NL/EMEA region, seamlessly connecting to the Global Tax Strategy and the underlying Global Transfer Pricing Policy for the ASML Group.
- Ensure the design, integration and maintaining of an effective and efficient intercompany pricing and intercompany financing structure for the NL/EMEA region, in compliance with all applicable tax laws and regulations.
- Provide efficient transfer pricing advice to senior management based on expected future developments, including advice on cross border transactions and merger and acquisitions.
- Participate in cross sector projects as representative of the Global Transfer Pricing team.
- Ensure the management of various NL and possibly global transfer pricing projects and outside consultants.
- Advice on Netherlands and international transfer pricing matters/regulations.
- Monitor and enhance the transfer pricing control framework for NL.
- Review Dutch transfer pricing compliance.
- Manage Transfer Pricing audits and Transfer Pricing exposures (in both transfer pricing specific audits and regular tax audit) in NL and provide support to management of such audits and exposures abroad to the extent required given the worldwide HQ being located in NL.
-Participate in the quarterly tax accounting process for determination of transfer pricing positions in NL (US GAAP Tax Provision).
- Review group structure and investments in light of changing international transfer pricing regulations (e.g. OECD Transfer Pricing Guidelines and BEPS) and derivative local legislation.
- Act as a soundboard for the tax manager Transfer Pricing for EMEA region.
- Contribute to the knowledge database as a corporate memory and communication tool and establish a network of outside counsel and specialists.
- Academic Dutch Tax Law or Economic Tax degree.
- Keen interest in developing and maintaining tax technical knowledge.
- 10+ years’ experience in international transfer pricing arena preferably as an inhouse transfer pricing counsel or within a big four environment or similar environment.
- Excellent understanding of the Dutch and international (OECD) transfer pricing regulations.
- More than average experience in managing dynamics and impact of transfer pricing solutions to corporate income tax and indirect tax areas.
- Experience with transfer pricing implications of designing and implementation of (changes in) a new operating model within a multinational company.
- Understanding of US GAAP tax accounting principles (preferred).
- Able to develop a vision and execute accordingly, able to weigh risks and benefits and act on these.
- Be a self-starter and ability work and function well in a team.
- Flexible, pro-active and communicative personality who is able to act as a professional business partner in a highly demanding and very busy technology environment.
- Strong drive with a hands-on, structured, accurate and result oriented working style.
- Excellent communication skills with the ability to clearly articulate transfer pricing matters to the interested lay person and ability to convince people.
- Ability to build relationships and influence other functional areas.
- A strategic mindset while having the ability to translate strategy into actionable objectives (short, medium and long-term).
- Team player with a flexible & pro-active attitude.
- Ability to cope with a multicultural, dynamic and changing environment.
- Strong analytical skills, with the ability to translate complex business issues into simple problem statements, clear processes and actions.
- Understanding of complex concepts and models, making the connection between managerial reporting and tax or transfer pricing impact.
- Good time management skills and able to manage towards tight deadlines.
- Ownership of issues from start to finalization.
- Fluent in English, both oral and written.
Approximately 10% of working time will be required for travel.
Context of the position
ASML’s Corporate Tax Affairs and Export Control team (hereinafter “ASML Tax”) currently includes 29 tax, customs and export control professionals residing in the Netherlands based worldwide HQ (16), the Hong Kong based regional HQ for Asia (7) and the US based regional HQ for US (5). ASML Tax is responsible for ASML’s fiscal, customs and export control affairs in all jurisdictions ASML operates in. Tax compliancy is the responsibility of Tax Support, which is reporting into the Finance Department and with a (strong) dotted line into ASML Tax. Like ASML Tax, Tax Support is regionally organized, with a Tax Support team located in the Veldhoven office. ASML Tax is accountable for the tax compliancy. Per January 2019 ASML Tax has internally established its Global Transfer Pricing Team being worldwide accountable for all transfer pricing matters and compliancy. Again, Tax Support is responsible for the compliancy. The flat ASML organization and X-sector approach for addressing business challenges allows ASML Tax and its Global Transfer Pricing Team to closely interact with the company operations, manage tax risks and provide for tax planning ideas according to the global Tax Strategy and underlying global Transfer Pricing Policy. Having entered into many unilateral and bilateral advance pricing agreement procedures with Netherlands and foreign tax authorities, ASML Tax has successfully worked on obtaining certainty on its transfer pricing positions and enhancing relationships with local tax authorities. New developments such as BEPS Action Plan 7 and 13 are closely monitored and acted upon when needed. The Netherlands based worldwide HQ covers NL and the EMEA region including EU jurisdictions, Israel and Russia.
Interested in this position? Please apply with cv and cover letter.