Global Transfer Pricing Leader and Policy Architect

To manage Transfer Pricing matters of the Group innovatively and strategically, define the Transfer Pricing Policy as well as recommend, advise and implement on solutions for complex transfer pricing projects and topics on a global scale as well as development of SGS Transfer Pricing Model. To ensure documentation of all significant international related party transactions across the SGS group of companies including all local and master transfer pricing documentation in accordance with local legislation, OECD guidelines and Base Erosion and Profit Shifting (BEPS) action plan. To ensure consistency between master file and local file documentation, and to implement a standardised process for the preparation of contemporaneous local transfer pricing documentation. Management of transfer pricing risks within the group including the risk of transfer pricing audit. Advise and support local finance managers and business units on the analysis, design, implementation and execution of Transfer Pricing Policy. Lead a transfer pricing team of currently 6 people in Poland and guide local finance managers on transfer pricing matters.

Global business activities in a MNE require a Global Transfer Pricing Model and Policy which need to be designed, developed, implemented, shaped globally and defended across all countries in which SGS is doing business. The pressure coming from all international developments in the transfer pricing area such as the release of the final BEPS action plan, acceleration of exchange of information among the tax authorities and other transparency initiatives require a position as Head of Global Transfer Pricing. With BEPS it has been introduced a mandatory and legally binding requirement for the completion of transfer pricing documentation across the majority of jurisdictions in which the SGS group operates. Under BEPS Action 13 a three tier approach to transfer pricing documentation is mandated: master file, local file and country by country report. In order to mitigate the risks within the transfer pricing area it will be necessary to establish a standardised documentation process. Furthermore, as tax authorities will have access to all three tiers of documentation it will be extremely beneficial to maintain a centralised function which can ensure the consistency of documentation and manage any requests for information or audit activity from tax authorities. Standardisation of the documentation process will also result in significant cost savings in relation to the preparation of local documentation as it will not be necessary to engage professional advisers in each jurisdiction to prepare locally compliant documentation.

Key Accountabilities

• Transfer Pricing Documentation Policy: Develop and maintain written policies and procedures relating to Transfer Pricing Documentation activities; Ensure documentation policy accounts for local deadlines, local documentation requirements and considers all key intra group transactions; Develop agreed process for transmitting transfer pricing documentation to tax authorities.
• Implementation and Development of the Transfer Pricing Model: Implement and develop the transfer pricing model of SGS in terms of all transactions covered by SGS group (commercial as well as inter‑company) in line with OECD standards including Intellectual property model development, regional costs allocation, TP benchmark studies and Process Contribution Analysis as well as supply chain analysis.
• Tax Audit Support and Advise: Manage the process of defending the Transfer pricing set up and model in each country towards the tax authorities incl. tax audits, advanced pricing agreements or any other TP related request. Assist local finance teams in the management of transfer pricing audits by local tax authorities and compile/review transfer pricing information provided to tax authorities.
• Lead of the Transfer Pricing Team in Poland: Manages and develops the Transfer pricing team by providing vision and strategic leadership and fostering an environment of growth and development within the transfer pricing area. Develop direct report in view of 'succession planning'.
• Business Partnering and Support for All Business Lines: Build a strong network with our external network partners like tax consultants and manage external stakeholders on transfer pricing questions such as external auditors.
• Training and Communication: Ensure appropriate internal and external training opportunities are available to direct reports; Provide training to local finance teams and business controllers on transfer pricing model, policy, documentation requirements and their responsibilities in relation to local filing requirements.
• Commercial Duties: Manage team budget and take responsibility for engaging external advisers to provide additional transfer pricing services as required; Manage performance and facilitate the development of direct reports.

Qualifications

12-15+ years of experience in Transfer Pricing / International Tax, ideally a mix of: Big 4 (or top‑tier advisory firm) - strong technical foundation Multinational company - in‑house experience managing global TP models. Proven experience in designing and implementing global TP policies and operating models. Hands‑on involvement in: Master File, Local File, and CbCR (BEPS Action 13) Global documentation standardisation projects Complex TP structures (IP, service models, cost allocation, principal structures). Experience managing transfer pricing audits, APAs, and tax authority negotiations across multiple jurisdictions. Exposure to highly regulated, multi‑country environments (ideally 50+ jurisdictions).