Responsibility for the group-wide transfer pricing framework for project activities in the USA, Chile, Poland, Spain, and Italy., Focus on operational design and documentation of transfer prices and ensuring lean international tax compliance., Strategic international tax issues resolved in close coordination with the Head of Tax and external advisors., Development, implementation, and ongoing maintenance of a pragmatic TP framework (methods, margins, guidelines) for management/O&M fees, project financing, and cost allocations according to OECD guidelines., Creation and updating of TP documentation (Masterfile/Roll-forward, transaction matrix, local files for significant transactions) and monitoring deadlines and documentation quality., Operationalization of TP requirements in intercompany agreements (service agreements, loans, cost allocations) and support with accounting implementation in SAP in coordination with finance managers of foreign markets., Building and operating a lean cross-border governance process: tax initial assessment of foreign contracts (service providers, project contracts, financing), PE/withholding tax screening, and documented tax sign-off process – complex international tax matters coordinated with the Head of Tax and advisors., Screening of foreign payments (interest, service fees, licenses) for withholding tax risks; management of double taxation agreement (DTA) utilization and exemption/reimbursement procedures in cooperation with the Head of Tax., Ensuring essential international reporting obligations (e.g., DAC6, § 138 AO) in coordination with the Head of Tax., Setting up simple monitoring routines (e.g., SAP evaluations, TP dashboards) for early detection of permanent establishment and withholding tax risks and escalating critical issues to the Head of Tax., Maintaining close ongoing coordination with the Head of Tax and finance managers of foreign markets and developing practical guidelines for procurement, legal, and project teams.
