Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy / Senior Manageress, EMEA Tax Planning, Transfer Pricing & Controversy

Job Opportunity: Senior Manager, EMEA Tax Planning, Transfer Pricing & Controversy

Aptiv is seeking a dynamic and experienced Senior Manager to support the Company's tax strategy across the EMEA region. In this pivotal role, you will be responsible for developing and implementing technically robust, commercially practical, and defensible tax solutions. You will manage transfer pricing, tax planning, and tax controversy matters across assigned jurisdictions.

The ideal candidate will lead complex international tax projects, including cross-border financing arrangements, transfer pricing governance, tax audits, controversy matters, and dispute resolution. This role requires close collaboration with various stakeholders, including Tax, Treasury, Finance, Legal, business leaders, tax authorities, and external advisors.

Position Responsibilities

Tax & Treasury Liaison

• Serve as the primary tax liaison to Treasury on funding, liquidity, capital structure, intercompany financing, leasing, and hedging transactions.
• Provide tax and transfer pricing guidance on financing arrangements and treasury initiatives.
• Advise on withholding tax, treaty interpretation, beneficial ownership, and other cross-border financing matters.
• Support the implementation of tax-efficient and commercially practical financing structures.
• Partner with Finance, Treasury, and Legal to ensure appropriate tax governance and documentation is maintained.

Tax Planning & International Tax

• Lead EMEA tax planning initiatives for assigned jurisdictions.
• Identify and evaluate tax planning opportunities arising from business operations, restructurings, and financing activities.
• Develop technically supportable and audit-defensible positions on international tax matters.
• Present tax planning opportunities, risks, and recommendations to senior tax leadership.
• Support legal entity rationalizations, restructuring projects, and operating model changes.
• Provide technical advice on international tax issues, including cross-border transactions and withholding taxes.
• Monitor developments in OECD guidance, EU tax developments, and local legislation.

Transfer Pricing

• Lead transfer pricing governance for financing, treasury, leasing, intellectual property, and other intercompany transactions.
• Oversee the development and maintenance of transfer pricing policies in accordance with OECD guidelines and local requirements.
• Coordinate transfer pricing documentation and defense strategies globally in collaboration with the Transfer Pricing team.
• Support the implementation of transfer pricing policies across business units and jurisdictions.
• Ensure appropriate governance and controls are maintained over intercompany arrangements.

APAs & MAPs

• Lead and manage Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).
• Develop technical positions and submissions for tax authorities.
• Coordinate internal stakeholders and external advisors throughout negotiations and dispute resolution processes.
• Support the resolution of double taxation and cross-border transfer pricing disputes.

Tax Controversy & Advocacy

• Lead the EMEA Tax Controversy Program for assigned jurisdictions.
• Manage tax inquiries, audits, appeals, litigation, and dispute resolution matters.
• Develop audit defense strategies and supporting documentation.
• Prepare technical memoranda and supporting evidence to defend material tax positions.
• Coordinate responses with tax authorities and external advisors.
• Maintain controversy assessments and reporting processes for management and compliance purposes.

Leadership & Stakeholder Management

• Lead complex multi-jurisdictional projects involving Tax, Treasury, Finance, Legal, and business leadership.
• Build and maintain strong relationships with tax authorities, external advisors, and internal stakeholders.
• Present complex technical matters clearly and effectively to senior management.
• Promote strong tax governance, documentation, and risk management practices across the region.

Requirements

Experience

• 10+ years of relevant experience in international tax, transfer pricing, tax planning, and tax controversy within a multinational corporation, Big Four accounting firm, and/or law firm.
• Significant experience managing complex cross-border tax matters across multiple jurisdictions.
• Expertise in transfer pricing, OECD guidelines, and governance.
• Proficiency in cross-border financing structures, treasury-related tax issues, withholding taxes, and treaty interpretation.
• Experience supporting multinational operations across EMEA.

Education & Professional Qualifications

• Degree in Law, Tax, Accounting, Finance, Business, or a related discipline.
• Master's degree or advanced professional qualification in Tax, International Tax, or a related field preferred.
• Advanced transfer pricing qualifications and/or demonstrated expertise in OECD transfer pricing principles highly desirable.

Skills & Competencies

• Excellent analytical, advocacy, and problem-solving skills.
• Strong written and verbal communication abilities.
• Ability to develop technically sound and commercially viable solutions.
• Proven leadership capabilities, influencing stakeholders across multiple functions and jurisdictions.
• Strong relationship management skills with both internal and external stakeholders.
• Fluent in English; proficiency in German is an advantage.

Apply online using the form below.

Only applications matching the job profile will be considered.

Aptiv is an equal employment opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, national origin, sex, gender identity, sexual orientation, disability status, protected veteran status, or any other characteristic protected by law.