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Senior Manager Transfer Pricing Controversy (all genders)
YOUR TASKS AND RESPONSIBILITIES
1. Co-lead Bayer’s global and German transfer pricing controversy strategy, ensuring alignment across business units and jurisdictions and support mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA), including negotiation strategy and documentation
2. Manage and support international tax audits by providing transfer pricing data, documentation, and strategic input aligned with Bayer’s global tax positions
3. Develop and implement data analytics and visualization solutions to support controversy cases and strategic decision-making
4. Collaborate with business modelling/partnering teams to ensure readiness and consistency in controversy scenarios
5. Support public reporting requirements (e.g., CbCR, OECD Pillar I) with robust data and narrative frameworks
6. Facilitate retrospectives and learning loops post-audit or controversy resolution to improve future readiness
7. Lead cross-functional initiatives to embed controversy readiness into business model design and tax governance
8. Coach junior team members and foster a culture of transparency, agility, and continuous learning
9. Represent Bayer in external forums and with tax authorities, maintaining integrity and strategic positioning
WHO YOU ARE
10. Tax specialist with university degree in Economics, Business Administration, Tax, or Law
11. Preferred Certified German Tax Advisor (StB), Chartered Financial Analyst (CFA), or equivalent Experience & Capabilities
12. Extensive experience in transfer pricing, with proven experience in controversy management, MAP/APA processes
13. Strong understanding of international and German TP regulations and audit practices
14. Demonstrated ability to lead complex, cross-border tax projects and defend positions under scrutiny Technical Skills
15. Proficiency in data analytics tools (PowerBI, Tableau, Alteryx, Knime) as well as familiarity with ERP systems (SAP), tax engines, and documentation platforms
16. Coaching mindset and ability to lead through ambiguity
17. Familiarity with skills frameworks and capability-based development
18. Fluent in English and German preferred
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