Senior Manager, Transfer Pricing, Open to flexible working

London (Central), London (Greater)
05 Jan 2021
26 Jan 2021
Contract Type


Group Tax is a global function, with specialists currently based in the UK, US, Netherlands, Ireland and Budapest - Our strategy is to optimise the Group’s tax position through appropriate tax planning and risk management, aligned with our commercial strategy and operating structures. Like almost all other Multinational Enterprises (MNEs), TP has become central and critical to the management of Diageo’s global tax risks. This is evidenced by the number and depth of TP related audits and questions we have received and responded to in the past 12 months.


Given the increasing importance of the topic, it is essential that Diageo has sufficiently qualified and experienced personnel to ensure that our policies and processes are technically strong and well governed. The TP Senior Manager -Technical role will work closely with the Tax Director for TP and Indirect Taxes, the TP Associate Director and TP Manager -Operations to develop and deliver Diageo’s global TP agenda. The TP Senior Manager -Technical role will have responsibility for providing specialist TP technical support, guidance and input to ensure Diageo’s TP model is compliant, sustainable end executed appropriately by the business. The role also has responsibility for supporting the business with defending the TP model. The TP Senior Manager -Technical must therefore have an in-depth technical understanding of all relevant guidance to provide high-quality TP advice to the business.

Top Accountabilities

  • Manage the global TP agenda, including: Reviewing and changing pricing policies where necessary (including our A&P policy, Inter Company Selling Prices, supply pricing, financial transactions etc.)
  • Management of TP audits (including the development and ownership of our response strategy)
  • Successfully implementing master/local documentation requirements (including necessary economic analysis and benchmarking)
  • Sharing responsibility for the relationship with our TP advisors
  • Support TP Manager - Operations in ensuring optimal execution and implementation of TP policies
  • Lead training for our global financial personnel so that they understand our TP policies and practices Manage ad-hoc market / business queries

Qualifications and Experience Required


  • ACA, CTA qualified, ADIT or equivalent economics-based qualification with at least 6years of transfer pricing experience in a consultancy/advisory business and/or an in-house tax department
  • In-depth understanding of the arm’s length principle, the OECD/UNTP Guidelines or business economics principles
  • Strong understanding of accounting and tax principles and reporting process
  • Commercially astute, analytically strong strategic thinker with the ability to evaluate complex financial data and an ability to distil complex concepts into clear and simple messages
  • Excellent but considered communication and influencing skills that facilitate effective networking and relationship building.
  • Inquisitive, patient and open to new ideas and ways of solving a problem

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