Head of Transfer Pricing UK/Europe

Last updated an hour ago
Location:Greater London


Role Title: Head of Transfer Pricing UK/Europe

Business: Human Resources

New or Existing Role- Replacement

Grade: GCB3

Role Purpose

    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 ad-hoc projects.

        Key Accountabilities

        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 respective remits.

            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 risk.

                To manage the TP aspects of head office costs, ensuring the correct levels of recharges are made and the business understands their obligations and responsibilities.

                  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 relating thereto.

                    Customers / Stakeholders

                    • 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 pricing matters.
                    • 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.

                                  Operational 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.

                                  Major Challenges

                                    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 data

                                                    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


                                                      Role Context

                                                        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 Controls

                                                          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.

                                                          Management Risk

                                                            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.