Title:

Asia Transfer Pricing Manager

Reporting Line:

Straight Line: Senior Director, Transfer Pricing

Required Experience:

Sound Transfer Pricing experience and China corporate income tax knowledge as well as PE knowledge.

China indirect tax exposures.

Work scope:

• Involved in all Asia Transfer Pricing matters.

Strategic work:

• Identify the regional Transfer Pricing risks in daily work and lead the regional Transfer Pricing audits.
• Monitor & Update TP review process during the year i.e. true up before year end and monitor the legal entity’s profitability on a monthly basis and coordinate with the Corporate Transfer Pricing team and external TP adviser if material profitability gap is identified during the year.
• Work with the Asia Senior Tax manager and external tax advisers to set up tax SOP for affiliate cross-border service charges, provide checklist for local FCs to follow up for remittance and provide support for compounding six beneficial tests and documentation for maximizing income tax deduction purposes.
• Perform as central contact person for addressing affiliate service charge questions in Asia
• Work with the Corporate TP team and the Asia Tax Senior Manager to produce and develop TP audit defense strategy for Asia affiliates.

Review work:

• Perform selected reviews of RPT information that was prepared by the local finance team in their annual tax filing PPT forms (19 forms), Statutory audit reports and TPD if any and provide feedback and suggestions for improvement (data accuracy and consistency).
• Prepare transaction summary sheet from PRC Statutory reports perspective for China’s 20+ legal entities.

Assistance with Local file requirements:

• Serve as a central control contact person for related-party services including providing an overview of related-party services, description of the service-related cost pooling method, and by noting similarities and differences between the related and unrelated services in terms of pricing policy and transaction results.
• Assist external advisers in documenting business strategies, including description of business processes, operation models, value drivers etc.
• Assist external advisers with value chain analysis (including description of group’s business flows, goods flows and cash flows, noting the business processes and participants in each process, including Financial statements of each participant involved for the most recent fiscal year, measurement and attribution of the contributions of location specific factors to the group’s value creation, principles and results of the distribution).
• Coordinate and monitor the disclosure of management structure (including the individuals to whom local management report and location of the office of these individuals).
• Assist and coordinate with external advisers and internal SBD personnel regarding business restructurings or intangibles transfers involving or affecting the enterprises, as well as their effects on the enterprise.
• Work with external advisers on the disclosure of related equity transfers.

Masterfile interpretation:

• Assist external tax advisers and internal finance controllership with review and translation of the Masterfile in China.
• Work with external tax advisers and Corporate Transfer Pricing team on how to provide/disclose information to China income tax authorities.

CBC reporting:

• Provide assistance and coordination with the Corporate income tax team and Asia Tax Senior Manager as well as the local finance team on any questions in relation to the CBC reporting from China tax bureaus.
• Assist the local finance team with reconciliations between CBC reporting and local statutory reporting if material gaps exist.

We Don’t Just Build The World, We Build Innovative Technology Too.

Joining the Stanley Black & Decker team means working in an innovative, tech-driven and highly collaborative team environment supported by over 43,500 professionals in 60 countries across the globe. Here, you’ll get the unique chance to impact some of the world’s most iconic brands including STANLEY TOOLS, DEWALT, CRAFTSMAN, MAC TOOLS and Black + Decker. Your ideas and solutions have the potential to reach millions of customers as we work together to write the next chapter in our history. Come build with us and take your career to new heights.

Who We Are 

We’re the World’s largest tool company. We’re industry visionaries. We’re solving problems and advancing the manufacturing trade through innovative technology and our Industry 4.0 Initiative. We are committed to ensuring our state-of-the-art “smart factory” products and services provide greater quality to our customers & greater environmental and social value to our planet. We are unique in that we have a rich and storied history dating back to 1843, but that hasn't stopped us from evolving into a vibrant, diverse, global growth company.

Global Benefits & Perks
You’ll be rewarded with a competitive salary plus receive entitlements and benefits unique to your country of hire. 

What You’ll Also Get

Career Opportunity: Career paths aren’t linear here. Being part of our global company with 60+ brands gives you the chance to grow and develop your skills along multiple career paths.

Learning & Development: 
Our lifelong learning philosophy means you’ll have access to a wealth of state-of-the-art learning resources, including our Lean Academy and online university (where you can get certificates and specializations from renowned colleges and universities).

Diverse & Inclusive Culture:
We pride ourselves on being an awesome place to work. We respect and embrace differences because that’s how the best work gets done. You’ll find we like to have fun here, too.

Purpose-Driven Company:
You’ll help us continue to make positive changes in the local communities where we work and live as well as in the broader world through volunteerism, giving back and sustainable business practices.