The Global Senior Tax Manager, Foreign Entities serves as a technical leader responsible for the full tax lifecycle of the EEE foreign locations. Beyond managing compliance and provision, this role is designed to apply tactical efforts to proactively identify opportunities that support the EEE global tax strategy established by the Global Director of Tax and CFO. This position ensures the execution, revision, and maintenance of all transfer pricing studies, guaranteeing defense and compliance across all jurisdictions where EEE has a presence. Additionally, this role acts as a key liaison for global projects with the parent company, partnering with Corporate Tax and the local foreign finance teams to drive synergy, consistency, and risk mitigation across the global footprint.
SPECIFIC JOB RESPONSIBILITIES / COMPETENCIES
Strategic Tax Planning Support: Proactively analyze foreign entity structures, transactions, and supply chains to identify tax savings, treaty benefits, and restructuring opportunities. Provide framework and actionable recommendations to the Global Director of Tax to improve tax efficiency.
Parent Company Collaboration: Lead and coordinate tax aspects of global projects in alignment with the parent company (Ebara Corporation). Ensure seamless communication and reporting on cross-border initiatives and group-wide tax strategies.
Transfer Pricing Execution: Direct the Global Transfer Pricing Manager and external advisors to ensure the timely completion and finalization of all transfer pricing studies, Master Files, and Local Files. Ensure intercompany transactions are properly documented, defensible, and regularly updated.
Business Advisory & Support: Support and advocate for global tax business advisory with other functional departments across foreign entities, establishing clear tax policies, practices, and procedures.
Global Compliance Ownership: Manage global tax compliance engagements to ensure 100% adherence to local tax laws in all foreign entities, regardless of size. Oversee the compliance calendar to prevent gaps, penalties, or missed filings.
Foreign Tax Provision Management: Manage and review tax provision calculations for all foreign entities under IFRS and coordinate with the Corporate tax team on the consolidated tax provision. Monitor and forecast effective tax rates of the foreign entities. Collaborate with Corporate tax team to evaluate and present ideas for effective tax rate optimization.
Audit Management: Lead the defense of foreign tax audits in coordination with local finance teams and external advisors to minimize exposure and resolve inquiries efficiently.
Global Minimum Tax (Pillar Two): Support and help lead the implementation and ongoing compliance of OECD BEPS 2.0 Pillar Two requirements.
Process Improvement: Develop and document standardized tax processes and procedures to ensure consistency across jurisdictions and reduce reliance on manual workflows.
Team Leadership: Supervise, mentor, and develop direct reports, fostering a culture of accountability and continuous improvement
NATURE OF THE JOB
Strategic & Operational: This role shifts between high-level strategy (planning/global projects) and operational execution (filing/audits).
Autonomy: This role will co-lead the development of policies and must have the ability to recognize international tax issues independently and collaborate to provide solutions.
Scope: Supports due diligence and tax research related to foreign expansion, business changes, and parent company initiatives.
CONTACT WITH OTHERS
Internal: Corporate Tax Team, All Finance Departments, Foreign Entity Controllers, Legal/Compliance, Internal Audit, Operations, HR, and Ebara Corporation (Parent Company).
External: Accounting firms, Tax authorities, External Consultants.
BACKGROUND AND EXPERIENCE
Education: Bachelor’s degree required; CPA or equivalent international designation and/or advanced degree preferred.
Experience: Seven to Ten years of International Tax experience, preferably with a public accounting firm and/or large multinational corporation.
Transfer Pricing: Demonstrated experience in managing and completing transfer pricing documentation lifecycles.
Technical Knowledge:
In-depth knowledge of international tax laws, regulations, and compliance requirements.
Knowledge of Global Minimum tax rules (OECD BEPS 2.0 Pillar Two).
Experience with Accounting for Income Taxes under IFRS reporting standards.
Systems: Experience with BNA tax research platform, ORACLE, and FCCS preferred.
Skills: Strong ability to research complex tax issues, document findings, and advocate for tax business advisory with other departments.
Base Location & Work Schedule
This is a full time permanent hybrid position based out of our office in Silchester RG7 2PQ, UK
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