Senior Manager - Transfer Pricing

Senior Manager - Transfer Pricing

The Senior Manager - Transfer Pricing is responsible to support the transfer pricing compliance, advisory and strategic needs, including operational oversight for the MTN Group and operating companies (Opcos) across various markets. Key responsibilities include:

• Custodian of Group Transfer Pricing Strategy, Mandates and Policies
• Responsible to advise, guide and support the transfer pricing requirements for driving compliance optimization and risk mitigation
• Transfer pricing advisory - related Deal Advisory and Specialist Tax Partnering services

The role reports into the General Manager, Transfer Pricing and ultimately the Group Executive Tax.

Context

MTNs purpose is to enable the benefits of a modern connected life to everyone. The MTN Group Strategy is anchored in building the largest and most valuable platform business with a clear focus on Africa. This rests on a scale connectivity and infrastructure business – mobile and fixed access networks in the consumer, enterprise and wholesale segments.

Within the changing tax, financial, regulatory and governance environment the SM: Transfer Pricing must ensure successful delivery in the context of:

• Diversifying telco-to-techco landscape
• Constant dynamics and local challenges in the economic, regulatory and legal environments and evolving industry ecosystems
• Evolving tax practices and standards across multiple jurisdictions
• Achieving top quartile operating efficiency and effectiveness through scale and common policies and processes
• Driving growth through business intelligence and standardization to maximize business impact
• Multi geographic landscape and cultural context
• Management of demanding customer and supplier expectations
• Enhancing MTN reputational position as a leading secure, reliable and safe network and system provider at OpCo level
• To assist the MTN Board and EXCO in protecting the assets, reputation and sustainability of the organisation for MTN to accomplish its objectives

Values

We at MTN are a purpose and value-led organisation. At MTN, we believe that understanding our people’s needs and aspirations is key to creating experiences that delight you at work, everyday. We are committed to fostering an environment where every member of our Y’ello Family is heard, understood and empowered to live an inspired life.

Our values keep us grounded and moving in the right direction. Most importantly, they keep us honest. It is not something we claim to be. It is in our DNA.

As an organisation, we consider it our mission to create an exciting and rewarding place to work, where our people can be themselves, thrive in positivity and ignite their full potential. A workplace that boosts creativity and innovation, improves productivity, and ultimately drives meaningful results. A workplace that is built on relationships and achieving a purpose that is bigger than us. This is what we want you to experience with us!

Our commitments go beyond an organisational promise. It is in our leadership and managerial ethos to meaningfully partner with our employees, customers and stakeholders with a vision to realise our shared goals.

Live Y’ello

• Lead with Care
• Can-do with Integrity
• Collaborate with Agility
• Serve with Respect
• Act with Inclusion

Responsibilities

• Key Performance Areas

• As part the Group Tax team, the role is responsible for delivering to a specialized Transfer Pricing portfolio.

• Group Transfer Pricing

• Input into the enterprise-wide Transfer Pricing Strategy, Mandate and Policy. Responsible for maintaining, reviewing and cascading the Group Policies to ensure alignment with regional tax law and legislations.

• Develop/provide input, maintain, and update Region-specific transfer pricing policy and guardrails.

• Oversee operations, accounting, and compliance in relation to transfer pricing policies.

• Evaluate cross-border transactions and recommend appropriate transfer pricing and tax applications.

• Provide expertise, advise and monitor transfer pricing compliance across the Group.

• Transfer Pricing Strategy

• Guide in the development and preparation of transfer pricing documentation (Master File, Local Files, Country-by-Country Reports (CbCR) and other related requirements, ensuring compliance with local and international regulations (OECD Guidelines, BEPS Action Plan, local tax laws).

• Oversee the preparation of transfer pricing policies and ensure they align with business models and commercial realities.

• Provide advice on the selection of transfer pricing methods for intercompany transactions and assess the arm’s length nature of pricing arrangements.

• Advisory and Regulatory Support

• Liaise with tax authorities on transfer pricing matters and handle tax audits related to intercompany pricing and arrangements.

• Maintain an understanding of evolving transfer pricing regulations and provide updates to senior leadership on potential risks or changes.

• Consult and advise Opcos on transfer pricing related issues.

• Assist Opcos to adhere to critical compliance requirements.

• Input into the Opco management team with respect to transfer pricing related change element and its impact, from both a tax strategic and operational level.

• Assist with driving the knowledge management process for the Opco and provide oversight on technical and operational trainings, based on service delivery / tax environment changes.

• Provide functional support and advisory services to business leaders on International Tax and Transfer Pricing matters.

Transfer Pricing Risk Management:

• Identify and manage transfer pricing risks associated with intercompany transactions and structures.

• Input into measures to mitigate risk and resolve issues that may arise in relation to transfer pricing audits or disputes.

• Business, Project, M&A, Strategic Initiatives and Special Responsibilities

• Support various strategic business initiatives with respect to the transfer pricing implications as relates to new entities / businesses.

• Work with external advisers and counsel on Deal Advisory and Transactions (as they relate transfer pricing), including M&A deals and transaction structuring, evaluation of local and foreign transfer pricing implications, compliance, assessments as it impacts Group Tax risk positions and exposures.

• Project manage specialized Technology, integration and automation initiatives as they pertain to group Transfer Pricing.

• Other Core Activities

• Foster positive and proactive transformation of MTN’s partnerships with external audit firms, revenue services and other key partners into value-creating, strategic relationships with mutual value exchange.

• Provide training to business leaders, Local Opco Tax teams and other relevant functional team members based on amendments on international and southern African tax laws, regulations and positions.

• Promote a ‘MTN centric’ and ‘partnership approach’ to develop strong relationships with other working groups and ensure adherence to Group governance.

• Departmental Performance Management and Reporting

• Participation in the monitoring of performance and alignment with divisional strategy including own business performance and improvements for future performance.

• Periodically review reports from the Opcos and other business units within the MTN Group.

• Staff Leadership and Management

• Manage team members, providing leadership, mentorship, growth and development path for the junior managers and provide active involvement and training of tax team members.

• Set clear objectives and goals for the team and enables the team to deliver and use operating mechanisms to continually assess progress and improve.

• Collaboration

Responsibility towards:

• Internal Stakeholders:
• Group Tax and Finance Team
• Group Exco
• Internal Audit and Risk and Compliance Teams
• Regional and Opco Executives
• Regional and Opco Finance Team
• External Stakeholders:
• External Service Providers
• Tax Authorities

Qualifications

Job Requirements

Education

• H. Dip Tax or equivalent
• CA (SA), CIMA or equivalent, B. Proc, BA LLB or equivalent
• Articles from a top 5 audit firm or at a law firm
• Master’s Degree in Tax Law advantageous
• Advanced Diploma in Transfer Pricing advantageous

Experience

• 10 years transfer pricing experience with 5 years-experience at management level
• Strong knowledge of international tax laws and transfer pricing guidelines (OECD, BEPS).
• Experience with transfer pricing documentation, including preparing and reviewing master files, local files, and CbCR.
• Proficiency in financial modelling, including advanced Excel skills (e.g., financial analysis, forecasting, and benchmarking).
• Experience in handling tax audits and transfer pricing disputes (Revenue Au