QUALIFICATIONS & SKILLS

• Qualified Accountant and/or tax professional (e.g., ACA, ACCA, CTA, or equivalent).
• Degree in Accounting, Finance, Law, Economics, or a related discipline; postgraduate qualification in taxation or transfer pricing is an advantage.
• Minimum of 5 years post-qualification experience in transfer pricing, international taxation, or tax controversy, ideally gained in a multinational environment or leading professional services firm.
• Hands-on experience managing complex tax audits, disputes, and controversy matters involving multiple jurisdictions.
• Demonstrable expertise in the negotiation and operation of APAs and MAPs, including direct engagement with Competent Authorities or international tax authorities.
• Strong analytical and problem-solving capabilities, with proven ability to manage complex, high-stakes tax disputes.
• Exceptional communication and negotiation skills, with the ability to build relationships with both internal and external stakeholders.
• Ability to manage multiple projects, adapt to changing priorities, and work under pressure to tight deadlines.
• Strategic mindset, with the capacity to anticipate risks and develop sound mitigation strategies.

ABOUT THE ROLE

Kerry Group is seeking an experienced and dynamic Group Transfer Pricing and Tax Controversy Manager to join our global tax team. This pivotal role will be at the forefront of managing the Group’s transfer pricing strategy, ensuring full compliance with international and domestic tax regulations, and expertly handling tax audits and controversies across multiple jurisdictions.
The successful candidate will play a critical part in safeguarding the Group’s interests in relation to transfer pricing matters, leading complex negotiations, and serving as a trusted point of contact with tax authorities, including direct engagement with Competent Authorities through Advanced Pricing Agreements (“APAs”) and Mutual Agreement Procedures (“MAPs”).

KEY RESPONSIBILITIES

• Develop, implement and maintain robust transfer pricing policies according to global regulatory standards and the Group’s commercial strategies.
• Provide strategic recommendations to senior management regarding transfer pricing planning opportunities.
• Lead global transfer pricing compliance, including all documentation, notifications and filings.
• Lead the defence and resolution of transfer pricing positions in global tax audits, working closely with both internal stakeholders and external advisers.
• Prepare and review responses to inquiries and information requests from tax authorities concerning transfer pricing matters.
• Develop, implement and maintain robust transfer pricing documentation to support the Group’s global activities and defend against scrutiny.
• Analyse complex intercompany transactions to ensure compliance with OECD guidelines and local requirements.
• Develop, implement, and continuously improve policies, controls, and procedures related to transfer pricing compliance and tax controversy management.
• Monitor international tax developments and assess the impact on the Group’s transfer pricing strategies, recommending and implementing adjustments where necessary.
• Build and maintain strong working relationships with cross-functional teams, including Finance, Legal, and Business Operations, to facilitate effective implementation of transfer pricing policies and tax controversy management.