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The Senior Manager, Tax Controversy role is central to protecting the company’s tax profile, managing financial and reputational risk, and contributing to the company’s influence on the evolving tax landscape. The successful candidate will shape the company’s engagement with tax authorities and policymakers around the world, while strengthening internal readiness and resilience.
 

The Opportunity:

As a Senior Manager, Tax Controversy, you will be responsible for leading and supporting the company’s global tax audits, disputes, tax authority engagement, and defense of the company’s direct and indirect tax positions across multiple jurisdictions.  You will report directly to the Global Lead for Tax Controversy. This role will own and coordinate all phases of tax audits and disputes, from initial information requests through resolution, while shaping best-practice frameworks and partnering with Government Affairs, Legal and Commercial teams to support and influence tax policy in key markets.
 

The ideal candidate is a senior tax professional with strong technical expertise in tax law, significant experience managing complex cross border controversies and regional tax disputes, proven negotiation skills, and a track record of developing robust audit defenses and acting as a trusted advisor to senior leadership.

What You’ll Do:

Tax Controversy & Audits Support: 

• Independently manage assigned tax controversy matters, including audits, notices, refund claims, appeals, and litigation.
• Act as the lead for assigned cases, setting strategy and overseeing end-to-end management from initial inquiry to resolution.
• Serve as the primary point of contact with tax authorities, external advisors, and internal stakeholders on assigned controversy matters.

Strategy, Technical Analysis & Defense

• Develop and implement effective strategies for resolving tax disputes and managing tax risk across jurisdictions.
• Analyze and interpret complex tax laws, regulations, treaties, and case law to support and defend the company’s tax positions.
• Prepare, review, and quality-control responses to tax authority inquiries, RFIs, and audit findings, ensuring technical accuracy and consistency.
• Draft and review persuasive arguments, legal memoranda, position papers, and documentation for dispute resolution, appeals, and litigation.

Tax Governance and Controls: Frameworks, Processes & Documentation

• Develop and maintain best-practice frameworks, playbooks, templates, and documentation standards for managing tax audits and controversy globally.
• Maintain comprehensive and well-organized documentation and records of all controversy-related activities in the region and globally.
• Support the company’s global tax strategy and ensure consistency in controversy management and messaging across jurisdictions.
• Drive the tax control framework, ensuring tax controls are designed, documented, executed and continuously improved to support compliant, defensible and audit-ready tax positions.
• Drive standardization, automation and simplification across tax processes, with a focus on improving the quality, consistency and evidentiary strength of tax data and documentation. 
• Incorporate AI-enabled ways of working in a practical and responsible manner, including improving velocity, consistency and scalability without compromising technical quality, audit readiness or risk management.
• Ensure governance and controls materially enhance controversy readiness, audit support, documentation quality and the defensibility of Agoda’s filed and reported tax positions.

Cross-Functional Collaboration & Policy Input

• Collaborate closely with internal Tax, Legal, Government Affairs, PR, Finance, and business teams to ensure aligned positions and coordinated responses.
• Monitor tax and policy developments globally and assess the potential impact on ongoing and future controversies.
• Provide technical input to policy and advocacy initiatives, working with Government Affairs and industry groups where relevant

 Controversy Readiness & Training 

• Support the identification, assessment, and communication of controversy-related tax risks, exposures, and mitigation actions.
• Promote tax controversy awareness and best practices within the Agoda Group and in collaboration with other BHI brands.
• Develop practical training materials and provide guidance for junior team members and other departments on tax controversy.
• Drive continuous improvement in controversy management processes, incorporating learnings from past audits and disputes into future risk mitigation
• Maintain clear, timely updates and case documentation for the Global Lead for Tax Controversy and relevant internal stakeholders.
   

Required Qualifications:

• Bachelor’s degree in Accounting, Finance, Law, or related field; advanced degree (JD, LLM, MST, or equivalent) preferred.
• Legal training (law degree or experience as a tax lawyer) strongly preferred
• Professional certification (CPA, Chartered Accountant, or equivalent) is an advantage.
• Minimum 8-10 years of relevant experience in tax controversy, audit defense, or tax litigation, in law firms, accounting firms or MNCs with significant experience in the Asia Pacific region (e.g., China, Japan, Korea, Southeast Asia, Australia, India). Experience with US and European tax matters would be an added advantage. 
• In-depth knowledge of tax laws, regulations, and dispute resolution processes.
• Demonstrated experience leading complex, multi-jurisdictional tax audits or disputes, including direct interaction with tax authorities.
• Proven ability to draft and review high-quality technical documentation (position papers, memos, correspondence with authorities).
• Excellent analytical, negotiation, and communication skills advocacy skills for use within Tax and Finance as well as with external stakeholders and tax authorities
• Ability to work independently and collaboratively in a fast-paced, multicultural environment. 
• Experience working effectively across cross-functional teams.
• Strong project management and organizational skills.
• Agility to quickly adjust to changing priorities, combined with the ability to balance multiple priorities.
• Proficiency in English required; additional Asia Pacific language skills are an advantage.

Why Join Us?

• Opportunity to work with a dynamic and experienced team
• Exposure to complex, high-profile tax matters across the Asia Pacific region and Globally
• Competitive compensation and benefits package
• Professional growth and development opportunities

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