Director, Transfer Pricing & Disputes

DePuy Synthes is recruiting fora Director Transfer Pricing & Disputes located in Leeds United Kingdom.

The DPS Global Tax Group is recruiting for a Director of Transfer Pricing and Tax Disputesbased in UK. Responsible for transfer pricing and tax disputes for global DPS organizationwith estimated $9-10B net trade sales. The position will report to the Senior Director TaxPlanning 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 documentationoperationalization of TP and TP defense and risk mitigation
Provide advice and support to global tax trade and business partners as requiredparticularly 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 aprocess to ensure TP models are properly executed maintained and documentedfrom 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 toTP policies and support efforts with respect to tax policy developments such asOECD developments including TP implementation and impact modeling
Assist in developing and executing strategies across the full range of global disputeresolution activities including audits MAPs APAs rulings and risk-managementinsight in planning and implementation. Effectively deploy and supervise externaladvisors

Create a globally applicable strategic approach to audits particularly with respectto transfer pricing. This will involve crafting and implementing a best-in-class auditapproach and coordination system including a globally consistent approach toachieving tax certainty through the use of administrative treaty-based and courtbased resolution mechanisms tax rulings prefiling agreements etc.
Effectively coordinate between tax and the business involving outside advisors andco-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 isthe 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 andissues
Identify assess and mitigate potential planning hazards based on transfer pricingand disputes experience.

Position Requirements:
A minimum of a bachelors degree is required preferably in Accounting Finance orEconomics
A minimum of 10 years of tax/business experience including 5 years of transferpricing 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 inquiriesincluding MAPs and APAs witness preparation and complex transfer pricing
disputes
Experience evaluating litigation hazards particularly in the context of assessing thefinancial impact and reserves ramifications of ongoing audits and developments
Excellent business partnering and communication skills - specifically the ability toeffectively communicate highly technical matters in clear simple language tobusiness partners around the world
Strong influencing and collaboration skills partnering with multiple stakeholdersacross the enterprise and external partners including a network of legal andeconomic advisors across the globe.

Ability to develop talent and lead teams across the enterprise

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 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 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.

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 internal employees contact AskGS to be directed to your accommodation resource.

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