Director, Transfer Pricing & Disputes in Leeds

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Johnson & Johnson announced plans to separate our Orthopaedics business to establish a standalone orthopaedics company, operating as DePuy Synthes. The process of the planned separation is anticipated to be completed within 18 to 24 months, subject to legal requirements, including consultation with works councils and other employee representative bodies, as may be required, regulatory approvals and other customary conditions and approvals. Should you accept this position, it is anticipated that, following conclusion of the transaction, you would be an employee of DePuy Synthes and your employment would be governed by DePuy Synthes employment processes, programs, policies, and benefit plans. In that case, details of any planned changes would be provided to you by DePuy Synthes at an appropriate time and subject to any necessary consultation processes.

DePuy Synthes is recruiting for a Director, Transfer Pricing & Disputes, located in Leeds, United Kingdom. The DPS Global Tax Group is recruiting for a Director of Transfer Pricing and Tax Disputes, based in UK. Responsible for transfer pricing and tax disputes for global DPS organization, with estimated $9-10B net trade sales. The position will report to the Senior Director, Tax Planning and Disputes.

Responsibilities include:

• Leadership Team member for the Tax Planning team, including participating in global enterprise tax meetings, as well as succession planning and calibration meetings at the Tax Planning team level.
• Lead, mentor, and develop a team of 2 tax disputes and transfer pricing specialists.
• Develop enterprise-level, global TP policy and risk management strategies.
• Collaborate with global tax and business partners across DPS to facilitate best-in-class planning and execution of transfer pricing policies, TP documentation, operationalization of TP, and TP defense and risk mitigation.
• Provide advice and support to global tax, trade, and business partners as required, particularly in the areas of supply chain tax planning, IP planning, intercompany service arrangements and transfer pricing policies, including acquisitions and divestiture transactions.
• Develop, implement, and maintain governance standards, as well as developing a process to ensure TP models are properly executed, maintained, and documented from a legal, operational, accounting, and tax compliance standpoint.
• Manage the overall relationship with co-source providers on US Section 6662, master file, and local file TP documentation.
• Educate Finance and business partners on the impacts of global tax law changes to TP policies, and support efforts with respect to tax policy developments, such as OECD developments, including TP implementation and impact modeling.
• Assist in developing and executing strategies across the full range of global dispute resolution activities, including audits, MAPs, APAs, rulings, and risk-management insight in planning and implementation. Effectively deploy and supervise external advisors.
• Create a globally applicable strategic approach to audits, particularly with respect to transfer pricing. This will involve crafting and implementing a best-in-class audit approach and coordination system, including a globally consistent approach to achieving tax certainty through the use of administrative, treaty-based, and court-based resolution mechanisms, tax rulings, pre-filing agreements, etc.
• Effectively coordinate between tax and the business, involving outside advisors and co-sourcing partners as appropriate, to respond to government requests for information, site visits, interviews, etc. The ability to see the big picture is key, as is the ability to craft strategic written responses and persuasive advocacy.
• Support valuations in DPS.
• Responsible for the intercompany contractual framework for DPS.
• Where appropriate, develop best-in-class approaches to recurring inquiries and issues.
• Identify, assess, and mitigate potential planning hazards based on transfer pricing and disputes experience.

Position Requirements:

• A minimum of a bachelor’s degree is required, preferably in Accounting, Finance or Economics.
• A minimum of 10 years of tax/business experience, including 5 years of transfer pricing and disputes experience, at an advisory firm or in-house experience at a major multinational corporation.
• Experience defending multinationals at the various stages of audits and inquiries, including MAPs and APAs, witness preparation, and complex transfer pricing disputes.
• Experience evaluating litigation hazards, particularly in the context of assessing the financial impact and reserves ramifications of ongoing audits and developments.
• Excellent business partnering and communication skills - specifically the ability to effectively communicate highly technical matters in clear simple language to business partners around the world.
• Strong influencing and collaboration skills, partnering with multiple stakeholders across the enterprise and external partners, including a network of legal and economic advisors across the globe.
• Ability to develop talent and lead teams across the enterprise.

Johnson & Johnson is an Equal Opportunity Employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, age, national origin, disability, protected veteran status or other characteristics protected by federal, state or local law. We actively seek qualified candidates who are protected veterans and individuals with disabilities as defined under VEVRAA and Section 503 of the Rehabilitation Act. Johnson & Johnson is committed to providing an interview process that is inclusive of our applicants’ needs. If you are an individual with a disability and would like to request an accommodation, external applicants please contact us via https://www.jnj.com/contact-us/careers, internal employees contact AskGS to be directed to your accommodation resource.