Job Specifications
Head of International Tax & Transfer Pricing – UK (fully remote)
As a Head of International Tax & Transfer Pricing based in the UK (work from home), you will be reporting directly to the Chief Accounting & Tax Officer. You will own the enterprise-wide strategy, governance, and execution for international tax planning, and controversy management, as well as the design and operationalization of global transfer pricing policies. You will work closely with the Head of Direct Tax compliance and provisioning and the Head of Indirect Taxes to ensure international tax positions and transfer pricing are correctly reflected in Convera’s tax returns and take our VAT position into account.
You will ensure the organization’s tax position is aligned with business objectives, compliant with evolving global regulations (e.g., OECD BEPS/Pillar Two, local TP rules), and optimized for sustainable value creation. In this leadership role, you will be a trusted advisor to executive management on cross-border structuring, PE risks, M&A (as required), financing, IP arrangements, supply chain design, and effective tax cashflow management.
You Will Be Responsible For
Strategy & Leadership
Define and continuously refine the global international tax and transfer pricing strategy, governance framework, and risk appetite in alignment with corporate objectives.
Help mentor a global team of tax professionals; establish clear group KPIs, development plans, and succession pipelines.
Alongside the CATO, act as senior advisor to the executive team on tax impacts of strategic initiatives (market entries, reorganizations, IP migration, financing, treasury, and operating models).
International Tax Management
Work with the Head of Compliance & Provisioning on global cash tax forecasting, and repatriation strategies; partner with Treasury, FP&A, and Controllership.
Lead design and oversight of cross‑border structuring, holding company strategies, financing arrangements, and IP ownership models.
Drive implementation planning and, once in the rules, ongoing compliance with OECD Pillar Two (GloBE) and BEPS measures; coordinate data collection, calculations, and safe‑harbor analyses.
Work with the Head of Compliance & Provisioning to input into global tax compliance, returns, and information reporting for corporate income tax, particularly around CFC regimes, interest deductions, withholding taxes, and hybrid mismatch rules.
Manage tax controversy, audits, and APAs/MAPs; develop defensible positions, documentation, and settlement strategies.
Transfer Pricing (TP)
Establish, implement, and maintain global TP policies consistent with arm’s‑length principles across services, financing, and intangibles.
Design and validate intercompany pricing methodologies (e.g., CUP, TNMM, Profit Split) and perform annual testing and adjustments.
Oversee global TP documentation (Master File, Local Files), benchmarking, and operational TP processes (e.g., intercompany invoicing, cost allocations).
Lead APAs where appropriate; manage TP audits and dispute resolution, including competent authority processes.
M&A, Reorganizations & Projects
Lead tax due diligence, structuring, integration, and post‑deal optimization for M&A, carve‑outs, and joint ventures.
Advise on supply chain transformations, principal company structures, and substance requirements.
Advise business on internal reorganisations and commercial direct tax questions.
Tax Operations, Technology & Data
Work With Oracle And Accounting Teams To
Help automate transfer pricing calculations.
Define and implement controls over tax-sensitive data for Pillar Two, TP, and statutory requirements; drive automation and analytics for timely, reliable reporting.
Stakeholder Management & Communication
Provide clear executive‑level communication on tax risk, cash tax drivers, audit exposure, and regulatory developments.
Build strong relationships with tax authorities, external advisors, and industry bodies; represent the company in relevant forums where needed.
Essential Experience /skills
You should apply if you have:
Around 12–15+ years of progressive experience in international corporate tax and transfer pricing within multinational groups and/or Big Four/leading advisory; significant leadership responsibility.
Advanced professional qualification: Chartered Tax Adviser (CTA), ACA/ACCA, or equivalent;
Demonstrable expertise in OECD BEPS and Pillar Two (GloBE) rules; hands‑on experience implementing global TP documentation (Master/Local Files) and defending TP positions.
Track record managing large, complex audits and controversies (including APAs/MAPs) across multiple jurisdictions.
Experience with tax aspects of M&A, IP planning, financing, and supply chain/operating model design.
Strong command of UK corporate tax regime, SAO, CIR, DPT, MDR/DAC6, withholding tax, and substance requirements.
Fluency in financial statements, Oracle, and tax technology/data; adept in translating complex tax rules into opera