Transfer Pricing Senior Specialist

Zakat, Tax and Customs Authority

Transfer Pricing Planning

Keep abreast of Transfer pricing policies, GAAP, and generally accepted auditing standards, procedures and techniques to remain current on updates in tax rules, parameters and reporting procedures
Follow the latest developments, news and updates of multinational organizations to ensure awareness of new tax practices adopted by businesses and incorporate in assessments and audit reviews
Build and maintain solid relationships with third parties data providers (CBCR, etc.)to facilitate information sharing on transfer pricing related insights

Transfer Pricing Assessment

Consolidate, categorize and prioritize Transfer pricing audit results and conduct high level review of documentation and functional analysis to confirm audit findings
Align with the transfer pricing audit team for cases that need additional investigations following spotted risks and identified noncompliance during reviews
Develop models for various transfer pricing arrangements made by multinationals and their subsidiaries to run different scenarios and identify cases that could lead to tax base erosion
Gather and analyze data from different sources (e.g. CBCR, ERAD, TP Doc, Industry reports) and liaise with internal stakeholders and international institutions to share advancements in tracking transfer pricing arrangements
Research industries to develop benchmarks and comparability assessments in order to analyze outcomes and formulate conclusions on taxpayers line of business, revenue streams and economic ownerships of intangibles (trademarks, licenses, technology, etc.)
Manage the proper implementation of transfer pricing risk assessment programs, derive high-level quantification of possible transfer pricing risks, and develop indicators of transfer mis-pricing and ensure proper dispatch to auditors
Review advance pricing agreements (Unilateral, Bilateral and Multilateral APAs) and defend ZATCA s position in complex transfer pricing audits

Audit Review

Revise Transfer pricing tax assessments and confirm assessment approach (actual, estimated, reduced) based on accounting and financial structures
Monitor objections and appeals and ensure coordination with Legal Affairs or AMANA to resolve disputes and support in key testimonies by providing clarifications on final audit findings and results
Maintain and update related systems and databases, ensure that all audit findings are administered and stored in a preserved manner in order to facilitate data exchange with internal stakeholders and other government agencies

Reporting and Support

Develop reports on high risk cases based on audit findings and communicate with relevant stakeholders
Coordinate with Legal Support function to align on ZATCA s technical position and tax-related laws, policies and regulations
Communicate with ZATCA s internal departments to provide assistance and information related to Transfer pricing assessments

Organization and Operations

Follow all relevant policies, processes and standard operating procedures so that work is carried out in a controlled and consistent manner
Help in solving escalated problems and provide needed support for junior team to ensure work is carried out in an efficient manner