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Senior Manager - Transfer Pricing APAC
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In a nutshell
Hong Kong, Hong Kong
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ASML’s Tax and Customs team (hereinafter “ASML Tax”) currently includes various tax and customs professionals
residing in the Netherlands-based worldwide HQ , the Hong Kong-based regional HQ for Asia and the US-based
regional HQ for the US. ASML Tax is responsible for ASML’s fiscal and customs 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 Plans 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. Global Transfer Pricing Team is expanding and we are looking for an seasoned
Transfer Pricing expert to focus on APAC Transfer Pricing matters.
The Senior Manager Transfer Pricing APAC will report to the Global Head of Transfer Pricing based in the
Netherlands, and will work together with the other members of Global Transfer Pricing Team on various transfer
pricing related topics and projects from a strategical and tactical point of view while focusing on the Asian region
(such as China, Taiwan, South-Korea, Malaysia, Japan and Singapore).
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. When being part of ASML
Tax, you’ll face demanding challenges and enjoy the freedom to operate and do what is good for the company.
- Contribute and ensure adherence to the regional policies for APAC region, seamlessly connecting to the Global Tax
Strategy and the underlying Global Transfer Pricing Policy for the ASML Group;
-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 APAC and possibly global transfer pricing projects and outside consultants (such
as advance pricing agreements procedures);
-Monitor and enhance the transfer pricing control framework for APAC;
-Manage Transfer Pricing audits and Transfer Pricing exposures (in both transfer pricing specific audits and regular
tax audit) in APAC;
-Participate in the quarterly tax accounting process for determination of transfer pricing positions in APAC (US GAAP
-Review group structure and investments in light of changing international transfer pricing regulations (e.g. OECD
Transfer Pricing Guidelines and BEPS) and local legislations in APAC countries;
-Contribute to the knowledge database as a corporate memory and communication tool and establish a network of
outside counsel and specialists.
- Academic reputed Tax Law or Economic Tax degree or the equivalent
- Keen interest in developing and maintaining tax technical knowledge
-Minimum of 10 years’ experience in international transfer pricing arena preferably as an in-house transfer pricing
counsel or within a big four environment or similar environment.
- Excellent understanding of the international (OECD) transfer pricing regulations and practiced in APAC countries.
- 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.
-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.
-Able to build relationships and influence other functional areas.
-A strategic mindset while having the ability to translate strategy into actionable objectives (short, medium and longterm).
-Team player with a flexible & pro-active attitude.
-Able 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 along with attention to details.
- 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
-Show ownership of issues from start to finalization.
-Fluent in English, both oral and written.
Approximately 10% of working time will be required for travel.