Princ. Specialist TP & TreasurySasol

Purpose of Job

• Manage Transfer Pricing, CFC's and Treasury compliance and planning for the group. Support the Head TP & International Tax to ensure that the business is tax compliant and to add value to the business of the group.

Recruitment Description / Key Accountabilities

• Responsible for managing and assisting in the development of transfer pricing design and audit defence strategies, including preparation of transfer pricing documentation. Draft transfer pricing reports / coordinate drafting of transfer pricing reports including economic and financial analysis to support the pricing policies of the group.
•  Ensure transfer pricing obligations (e.g. documentation) are filled under local transfer pricing laws and regulations. Prepare, maintain, carry out and manage the implementation of transfer pricing policies in line with the tax policy of the company.
• Working closely with the business platforms and management to ensure proper reflection of intragroup transactions and assist with the implementation of appropriate methodologies, including reviewing of contracts. Advice the business on tax risks created by transfer pricing issues and on the implications for the group’s tax position.Provide support to GTS members in relation to the continuous developments in the local transfer pricing regulatory obligations in the various jurisdictions (strengthening tax administration of transfer pricing - transfer pricing related tax return disclosures and documentation in the various jurisdictions). Monitor global transfer pricing developments/trends (OECD BEPS (Base Erosion and Profit Sharing) TP (Transfer Pricing) documentation requirements Action 13) - develop internal tools and strategies that will ensure compliance with the new transfer pricing documentation obligations that are over and above transfer pricing reports.
• Responsible for managing and advisory on Controlled Foreign Companies ('CFC') implications for the group - CFC analysis, audit defence strategies, including preparation and review of CFC tax calculations. Advise the business on the tax risks created by Controlled Foreign Companies (CFC) issues and on the implications for the group’s tax position.
• Advise the business on tax risks created by Permanent Establishment and Place of effective management issues and on the implications for the group’s tax position.
• Ensure proper treatment and management of statutory tax matters, tax return preparation and compliance, accounting for taxes and payments for allocated entities or divisions, including current and deferred tax charge for financial reporting purposes. Manage relevant tax enquiries and audits, prepare responses to Revenue Authorities queries. Manage Tax compliance for jurisdictions with no GTS representative.
• Advise and support the business platforms, management and accounting departments on overall tax matters (TP, Direct and other matters) - review local tax returns (Gabon, Nigeria, Australia, India - other smaller winding down jurisdictions - assist with deregistration and liquidation obligations).
• Ensure that all treasury activities i.e. cash management, funding arrangements, equity transactions etc are fully compliant from a tax perspective for the treasury companies.
• Ensure lending and borrowing rates, credit risk analysis, terms and conditions of funding arrangements are arm length for tax purposes.

Formal Education

• University Bachelor's Degree
• Postgraduate degree in Tax and Transfer pricing

Min Experience

• Experience: 12+ relevant years