This is a fabulous, Transfer Pricing led, Head of International Tax opportunity in a market-leading global FinTech.
The role would suit either a senior Transfer Pricing specialist who is looking take on a broader international tax leadership position, or an existing Head of Tax / Head of International Tax who has a strong leaning towards transfer pricing issues in their current role. The ideal candidate will have a strong background in transfer pricing (intellectual property of software and/or TP of debt would be perfect); FS experience would be useful (or experience of working in an organisation with irrecoverable VAT). In addition, you will need a very good understanding of international tax in a UK outbound context (PE's, Pillar 2, CBCR) etc. You will be a trusted advisor to executive management on cross-border structuring, PE risks, M&A (as required), financing, IP arrangements, supply chain design, and effective tax cashflow management.
Key Responsibilities
* Define and continuously refine the global international tax and transfer pricing strategy, governance framework, and risk appetite in alignment with corporate objectives.
* Act as senior advisor to the executive team on tax impacts of strategic initiatives (market entries, reorganizations, IP migration, financing, treasury, and operating models).
* Lead design and oversight of crossborder structuring, holding company strategies, financing arrangements, and IP ownership models.
* Drive implementation planning and, once in the rules, ongoing compliance with OECD Pillar Two (GloBE) and BEPS measures; coordinate data collection, calculations, and safeharbor analyses.
* Establish, implement, and maintain global TP policies consistent with arm'slength principles across services, financing, and intangibles.
* Oversee global TP documentation (Master File, Local Files), benchmarking, and operational TP processes (e.g., intercompany invoicing, cost allocations).
* Lead APAs where appropriate; manage TP audits and dispute resolution, including competent authority processes.
* Lead tax due diligence, structuring, integration, and postdeal optimization for M&A, carveouts, and joint ventures and advise on internal reorganisations.
* Define and implement controls over tax-sensitive data for Pillar Two, TP, and statutory requirements; drive automation and analytics for timely, reliable reporting.
* Build strong relationships with tax authorities, external advisors, and industry bodies; represent the company in relevant forums where needed.
You will need to be an experienced international tax leader with experience across transfer pricing and international corporate tax within multinational groups and/or Big 4. You will need to be ACA/ACCA/CTA qualified and have demonstrable expertise in OECD BEPS and Pillar Two (GloBE) rules. In addition you will need to have hands on experience of implementing global TP documentation (Master/Local Files) and defending TP positions. It is important to have experience of managing large, complex audits and controversies (including APAs/MAPs) across multiple jurisdictions. A strong command of the UK corporate tax regime, SAO, CIR, DPT, MDR/DAC6, withholding tax is also key.
The ideal candidate will have experience in regulated or capital intensive industries (e.g., technology, fintech, financial services, life sciences, consumer goods).