Role Title: Head of Transfer Pricing UK/Europe
Business: Human Resources
Existing Role- Replacement
The role holder should have a vision, strategy and structure of
how the group should manage its transfer pricing in thecurrent and rapidly
changing commercial and economic environment. The latest technological
solutions should be utilised.
Responsible for managing the Regional and Local Tax functions
(Europe/UK) in managing the transfer pricing issues of the HSBC Group entities
in all the jurisdictions it operates in, including the formulation of transfer
pricing policies, guidance and recommendation on policy implementation.
The role holder will also have responsibility for advisory and
Impact on the Business
Working closely with the Global Head to Transfer Pricing to
provide guidance to Group entities and regional tax centre to ensure those entities
have appropriately implemented transfer pricing policy, and to identify,
document and periodically review intra-group transactions within their
To formulate, within context of Group’s overall transfer pricing approach
policies, procedures and practices regarding the pricing and documentation of
all intra-group transactions and recommend implementation procedures.
To be aware of the direct and indirect tax implications of
operating in an increasingly diverse and challenging commercial, regulatory and
tax environment and take appropriate action to mitigate the transfer pricing
To manage the TP aspects of head office costs, ensuring the
correct levels of recharges are made and the business understands their obligations
To be responsible for compliance with the OECD’s guidance on Base
Erosion and Profit Shifting (BEPS).
Responsible for identifying uncertain tax positions and resolving disputes
- To represent and
advise the Group on transfer pricing matters and influence decisions taken
in negotiations with Government Bodies, Tax Authorities, Trade Associations
and Statutory Auditors.
- To develop a clear
understanding of business needs and expectations and develop appropriate
transfer pricing solutions that support their requirements.
- To ensure that the
tax team (globally & regionally) are kept up to date with transfer
- Report to Global
Head of TP on TP matters and provide recommended actions.
Leadership & Teamwork
Act as the entity/function manager for the UK TP team.
Lead and develop an effective team through effective
Communication and Engagement, Performance Management, development
plans Reward/Recognition practices, Talent and Succession Planning Management.
To develop strong working relationships with other Group Tax personnel
and regional tax centres.
Promote an environment that supports Diversity and Inclusion and
reflects the HSBC brand.
Displays strong people management capabilities and acts as a role
model for the Bank’s Values and Behaviours.
Building strong, working relationships with local CFOs, local CEOs,
local CROs and local Finance teams, raising awareness of current and potential
tax issues and proposing, driving and delivering solutions as appropriate.
Effectiveness & Control
- To exercise best
judgment with regard to the application of conflicting business,
regulatory and fiscal imperatives.
- To produce and
champion best practice controls and documentation standards to allow the
Group to achieve optimal standards of transfer pricing compliance.
- To contribute to
Group’s risk and control framework.
Constant changing regulatory environment
Aggressive tax authorities trying to raise revenues
Manage the global Transfer Pricing team and ensure there is a
robust risk management
framework in place in respect of Transfer Pricing
A clear vision and understanding of not just the taxes but also
the legal, compliance and regulatory requirements
Commercial awareness and sound judgment are required in balancing
the needs of various business lines to operate competitively and the need to
ensure that the Group’s good reputation is preserved.
Detailed knowledge of complex legislation is required together
with an awareness of how the legislation is applied in practical situations.
Deploying technological solutions to streamline the analysis of
The ability to evaluate complex and competing legal, commercial,
fiscal and system imperatives and recommend a clear course of action
People – maintaining and recruiting the best in class
The role holder will be driving forward the groups transfer
pricing strategy, and engaging with senior stakeholders across the bank. The
rapidly changing economic and regulatory environment will make the role both
interesting and challenging and the successful candidate should expect to be
engaged on a diverse range of projects whilst managing a team.
Observation of Internal
The jobholder will also adhere to and be able to demonstrate
adherence to internal controls. This will be achieved by adherence to all
relevant procedures, keeping appropriate records and, where appropriate, by the
timely implementation of internal and external audit points, including issues
raised by external regulators.
The jobholder is responsible for ensuring that there is an
effective tax risk management framework in place. Pro-active tax risk
management and robust internal controls are essential in this regard.
The jobholder will also continually reassess the operational risks
associated with the role and inherent in the business, taking account of
changing economic or market conditions, legal and regulatory requirements,
operating procedures and practices, management restructurings, and the impact
of new technology. This will be achieved by ensuring all actions take account
of the likelihood of operational risk occurring and by addressing any areas of
concern in conjunction with line management and/or the appropriate department.