Senior Manager - Transfer Pricing at MTN

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.

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 Authority experience will be advantageous)