JOB PURPOSE:
The Tax Manager plays a pivotal role in developing, implementing, and managing ADNOC’s global transfer pricing (TP) framework. This position is responsible for establishing TP processes, policies, governance structures, comprehensive documentation, and operational procedures from the ground up within a complex multinational organization. The Tax Manager delivers expert technical advice on all TP matters, drives strategic projects, ensures adherence to OECD and UAE Corporate Tax regulations, and collaborates closely with Finance, Legal, Treasury, Supply Chain, and various business units to maintain robust and sustainable transfer pricing practices across the ADNOC Group.
KEY ACCOUNTABILITIES
Job Specific Accountabilities
Transfer Pricing Policy & Framework Development
- Create ADNOC’s global transfer pricing (TP) governance structure from the ground up.
- Formulate TP methodologies tailored to the functions, assets, and risk profiles of upstream, downstream, trading, shipping, procurement, and service units.
- Establish TP standards that meet OECD Guidelines, UAE Corporate Tax regulations, and relevant local TP rules.
- Map and document all intercompany transaction flows, covering goods, services, financing, intellectual property, and cost allocations.
- Ensure TP policies comply with economic substance requirements across all jurisdictions.
Operational Transfer Pricing
- Develop operational TP procedures such as data extraction, allocation methods, true-up processes, and year-end adjustments.
- Collaborate with Finance and ERP teams to configure systems for TP compliance and accurate reporting.
- Draft and implement Standard Operating Procedures (SOPs) for TP activities throughout ADNOC Group entities.
Documentation & Compliance
- Oversee the creation of Master Files, Local Files, benchmarking reports, Country-by-Country Reporting (CbCR) data, and TP disclosures.
- Develop internal templates, workflows, documentation repositories, and global compliance calendars.
- Guarantee uniform application of TP policies across all ADNOC subsidiaries and international operations.
Advisory & Business Partnering
- Provide guidance to business units regarding TP impacts of restructurings, supply chain adjustments, and new business models.
- Review and support the drafting of intercompany agreements to align with TP policies.
- Assist with M&A and JV integration, including TP due diligence and post-transaction implementation.
Audit, Controversy & Risk Management
- Prepare TP defense files and handle TP audits and regulatory inquiries.
- Support Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), negotiations with tax authorities, and the development of robust TP positions.
- Maintain TP risk registers and design mitigation strategies.
Systems & Data Governance
- Define TP data architecture and requirements for seamless ERP integration.
- Develop and implement automation solutions for TP calculations, analytics, and reporting.
- Lead data quality initiatives to enhance operational TP and documentation standards.
Leadership & Team Development
- Mentor junior staff and assist in recruiting TP specialists.
- Foster collaboration across Finance, Legal, Treasury, and Operations teams to strengthen TP practices.
Generic Accountabilities
Supervision
- Plan, supervise and coordinate all activities in the assigned area to meet functional objectives.
- Train and develop the assigned staff on relevant skills to enable them to become proficient on the job and deliver the respective business objectives.
Budgets
- Provide input for preparation of the Function / Division / Department / Section budgets, assist in the implementation of the approved Budget, and work plans to deliver business objectives.
- Investigate and highlight any significant variances to support effective performance and cost control.
Policies, Systems, Processes & Procedures
- Implement approved Function/ Division/ Department/ Section policies, processes, systems, standards and procedures in order to support execution of the work programs in line with Company and International standards.
Performance Management
- Contribute to the achievement of the approved Performance Objectives for the Function/ Division / Department/ Section in line with the Company Performance framework.
Innovation and Continuous Improvement
- Design and implement new tools and techniques to improve the quality and efficiency of operational processes.
- Identify improvements in internal processes against best practices in pursuit of greater efficiency in line with best industry standards in order to define intelligent solutions for issues confronting the function.
Health, Safety, Environment (HSE) and Sustainability
- Comply with relevant HSE policies, procedures, controls, applicable legislation, and sustainability guidelines in line with international standards, best practices and ADNOC Code of Practices.
Reports
- Provide inputs to prepare MIS and progress reports for Company Management.
COMMUNICATIONS & WORKING RELATIONSHIPS:
Internal
- Regular contact with Vice President, International Corporate Tax
- Communication with different functions in Corporate F&I
External
- Regular interactions with GCs Finance units
- Communication with partners and shareholders
QUALIFICATIONS, EXPERIENCE, KNOWLEDGE & SKILLS: Minimum Qualification
Bachelor’s degree in accounting, finance, economics, or a related field.
Minimum Experience & Knowledge & Skills
- 12 years’ transfer pricing experience with a combination of Big Four and multinational in‑house roles.
- Proven ability to build TP frameworks, processes, and documentation from the ground up.
- Deep knowledge of OECD Guidelines, UAE Corporate Tax TP rules, and major international TP regimes.
- Strong experience with TP documentation, benchmarking, operational TP, and intercompany agreements.
- Experience with TP controversy, APAs/MAPs, and authority negotiations.
- Advanced Excel/data skills and familiarity with ERP systems (SAP/Oracle).
- Professional qualification such as ACA, ACCA, CPA, CTA, or equivalent preferred.