Key Performance Areas
As part the Group Tax team, the role is responsible for delivering to a specialized Transfer Pricing portfolio.
Group Transfer Pricing
Input into the enterprise-wide Transfer Pricing Strategy, Mandate and Policy. Responsible for maintaining, reviewing and cascading the Group Policies to ensure alignment with regional tax law and legislations.
Develop/provide input, maintain, and update Region-specific transfer pricing policy and guardrails.
Oversee operations, accounting, and compliance in relation to transfer pricing policies.
Evaluate cross-border transactions and recommend appropriate transfer pricing and tax applications.
Provide expertise, advise and monitor transfer pricing compliance across the Group.
Transfer Pricing Strategy
Guide in the development and preparation of transfer pricing documentation (Master File, Local Files, Country-by-Country Reports (CbCR) and other related requirements, ensuring compliance with local and international regulations (OECD Guidelines, BEPS Action Plan, local tax laws).
Oversee the preparation of transfer pricing policies and ensure they align with business models and commercial realities.
Provide advice on the selection of transfer pricing methods for intercompany transactions and assess the arm's length nature of pricing arrangements.
Advisory and Regulatory Support
Liaise with tax authorities on transfer pricing matters and handle tax audits related to intercompany pricing and arrangements.
Maintain an understanding of evolving transfer pricing regulations and provide updates to senior leadership on potential risks or changes.
Consult and advise Opcos on transfer pricing related issues.
Assist Opcos to adhere to critical compliance requirements.
Input into the Opco management team with respect to transfer pricing related change element and its impact, from both a tax strategic and operational level.
Assist with driving the knowledge management process for the Opco and provide oversight on technical and operational trainings, based on service delivery / tax environment changes.
Provide functional support and advisory services to business leaders on International Tax and Transfer Pricing matters.
Transfer Pricing Risk Management:
Identify and manage transfer pricing risks associated with intercompany transactions and structures.
Input into measures to mitigate risk and resolve issues that may arise in relation to transfer pricing audits or disputes.
Business, Project, M&A, Strategic Initiatives and Special Responsibilities
Support various strategic business initiatives with respect to the transfer pricing implications as relates to new entities / businesses.
Work with external advisers and counsel on Deal Advisory and Transactions (as they relate transfer pricing), including M&A deals and transaction structuring, evaluation of local and foreign transfer pricing implications, compliance, assessments as it impacts Group Tax risk positions and exposures.
Project manage specialized Technology, integration and automation initiatives as they pertain to group Transfer Pricing.
Other Core Activities
Foster positive and proactive transformation of MTN's partnerships with external audit firms, revenue services and other key partners into value-creating, strategic relationships with mutual value exchange.
Provide training to business leaders, Local Opco Tax teams and other relevant functional team members based on amendments on international and southern African tax laws, regulations and positions.
Promote a 'MTN centric' and 'partnership approach' to develop strong relationships with other working groups and ensure adherence to Group governance.
Departmental Performance Management and Reporting
Participation in the monitoring of performance and alignment with divisional strategy including own business performance and improvements for future performance.
Periodically review reports from the Opcos and other business units within the MTN Group.
Staff Leadership and Management
Manage team members, providing leadership, mentorship, growth and development path for the junior managers and provide active involvement and training of tax team members.
Set clear objectives and goals for the team and enables the team to deliver and use operating mechanisms to continually assess progress and improve.
Job Requirements
Education:
H. Dip Tax or equivalent
CA (SA), CIMA or equivalent, B. Proc, BA LLB or equivalent
Articles from a top 5 audit firm or at a law firm
Master's Degree in Tax Law advantageous
Advanced Diploma in Transfer Pricing advantageous
Experience:
10 years transfer pricing experience with 5 years-experience at management level
Strong knowledge of international tax laws and transfer pricing guidelines (OECD, BEPS).
Experience with transfer pricing documentation, including preparing and reviewing master files, local files, and CbCR.
Proficiency in financial modelling, including advanced Excel skills (e.g., financial analysis, forecasting, and benchmarking).
Experience in handling tax audits and transfer pricing disputes (Revenue Authority experience will be advantageous)
