Job Description

About the Company:
ADNOC Distribution is on a journey to change the retail landscape, delivering tangible actions to facilitate progress in providing sustainable mobility solutions for our customers. We are taking bold and transformative steps to grow our domestic and international footprint for our customers. We are customer-centric, offering digitally enabled journeys and providing innovative products and services to drive accelerated and sustainable development for the future of mobility.
ADNOC Distribution markets, sells, and distributes transportation fuel to both retail and commercial customers. We also run non-fuel services at our service stations.
About the Job:
Provide specialist subject matter services to ensure transfer pricing & international tax compliance, optimize tax strategies and support international tax planning. Collaborate with cross-functional teams and external advisors to ensure ADNOC Distribution and its subsidiaries are in compliance with transfer pricing & international tax regulations.
Job Specific Accountabilities
International Tax & Transfer Pricing Advisory

• Work with advisors to assess tax implications of foreign expansion plans including but not limited to tax structuring, permanent establishment risk assessments and withholding tax.

• Work with advisors on tax due diligence and relevant tax aspects of post-merger integration pertaining to foreign merger and acquisition (M&A) activities.

• Support to address the relevant Organization for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) requirements, including but not limited to Country-by-Country reporting (CbCR) and BEPS Pillar Two.

• Handle operational day-to-day activities with International Tax and transfer pricing impact; provide tax advice and support to the various business units to ensure full compliance with the relevant Tax laws.

• Responsible for the development and implementation of the relevant International Tax policies and procedures.

International Tax Compliance

• Monitor and stay up to date with international tax laws, treaties, and regulations in relevant tax jurisdictions where ADD operates in.

• Responsible for the International tax compliance process, including liaising with local tax teams to ensure all required international tax returns, including corporate income tax, withholding tax, value-added tax (VAT), and other country-specific taxes returns, payments and supporting documentation are complete and accurate, up to date, on file, and where required, submitted on time in collaboration with the local tax accountants.

• Ensure compliance with various country-specific tax reporting requirements, including Transfer Pricing Documentation (Transfer Pricing Disclosure form, Master File and Local File) and Country-by-Country Reporting (CbCR).

• Manage process to apply for preferential WHT rates and refunds as per the applicable tax treaty.

• Track and monitor foreign taxes paid and mitigate impact of double taxation as applicable.

Transfer Pricing compliance and Documentation

• Develop and implement transfer pricing policies that align with arm's length principles and meet the requirements of various tax jurisdictions.

Prepare and maintain UAE transfer pricing return & documentation (Disclosure form, Master File and Local File) to support intercompany pricing and comply with local transfer pricing regulations.

Monitor intercompany transactions to ensure consistency with transfer pricing policies.

Handle transfer pricing policy reviews with relevant business functions and external advisors to ensure timely updates to the transfer pricing policy and intercompany agreements as necessary depending on business developments.

Support the operational transfer pricing review of intercompany recharge cross-border recharges.

Support Advance Pricing Agreement application with support of external advisor where applicable.

Support Transfer Price Benchmarking as and when required.
International Tax Planning and Optimization:

Collaborate with cross-functional teams to develop international tax strategies that align with the company's global business objectives and minimize tax liabilities.

Analyze the tax implications of international business activities, mergers, acquisitions, and restructurings to optimize tax efficiency.

Identify tax planning opportunities such as tax credits, incentives, and tax-efficient repatriation.
Tax Treaty Analysis and Benefits

Analyze tax treaties between the relevant countries to determine the most advantageous tax treatments for cross-border transactions and activities.

Ensure that the company maximizes the benefits available under tax treaties to prevent double taxation and minimize tax costs.

Optimize foreign tax credits to avoid double taxation on foreign income and ensure compliance with foreign tax credit rules and limitations.
International Tax Risk Management and Internal Control

Establish and maintain robust internal controls to manage international tax risks and ensure compliance with tax laws.

Monitor potential international tax exposures and develop strategies to mitigate risks effectively.
Monitoring Local & International Tax Developments and Ensure Compliance

• Monitor international tax and transfer pricing developments and provide relevant updates to relevant stakeholders in a timely manner.

• Implement measures to ensure compliance with the OECD BEPS initiatives and country-specific anti-BEPS regulations.

Audits and Dispute Resolution

• Support the team during transfer pricing audits conducted by Tax Authorities in the relevant tax jurisdictions.

• Respond to transfer pricing inquiries and information requests from tax authorities promptly and accurately.

• Engage in transfer pricing dispute resolution processes and defend the company's transfer pricing policies during audits and appeals.

• Support local tax team with any information and documentation requests received from the Tax Authority conducting the Tax Audit on foreign jurisdiction tax compliance.

• Ensure the implementation of remediation measures required to address applicable outcomes of Tax Authority audits or queries on foreign jurisdiction WHT, foreign jurisdiction Transfer Pricing and foreign jurisdiction direct tax.

Relationship Management

• Develop and maintain effective business relationships with all relevant external/internal entities such as tax authorities, external tax advisors, financial regulators and government authorities etc with highest standards of business ethics, whilst promptly attending to all critical issues in-order to ensure the services required by the organization are delivered in the most effective manner.

• Identify improvements in internal processes against best practices in pursuit of greater efficiency in line with ISO standards to define intelligent solutions for issues confronting the function.

Health, Safety, Environment (HSE) and Sustainability

• Comply with relevant HSE policies, procedures & controls and applicable legislation and sustainability guidelines in line with international standards, best practices and ADNOC Code of Practices

Reports

• Provide inputs to prepare Section MIS and progress reports for Company Management

Minimum Requirements:

• Bachelor's degree in finance, law or relevant discipline

Minimum Experience & Knowledge & Skills

• 8 years of relevant experience
• Experience in Big4 is preferred.
• Solid understanding of international tax laws, regulations, and transfer pricing concepts
• Excellent communication and interpersonal skills to work effectively within cross-functional teams and external partners.
• Ability to adapt to evolving international tax laws and regulations.
• Familiarity with global tax implications and tax treaties
• Practical understanding of tax touchpoints risk areas affecting general business workflows, processes, and operations processes.
• Strong analytical and problem-solving skills.
• Demonstrate good research skills.
• Good project management skills

Skills Required