Support countries in the region as and when necessary:
- during tax inspection - providing documents and reviewing answers to the authorities, meetings and negotiation with authorities, etc.
- after tax inspection - review of assessment notes, support appeals, court cases, meetings and negotiation with authorities, etc
- ad-hoc questions during the preparation of tax returns or during external audit
- support countries on local tax compliance, in particular transfer pricing documentation in collaboration with the Head of Transfer Pricing and withholding tax
- quarterly review of tax reporting (Form 18) incl. detailed analysis of deferred tax, prior year adjustments, tax losses, effective vs. statutory tax rates, tax risks, etc. on a country-by-country basis
- managing local tax risks and provisioning required for consolidated financial statements of group (regular monitoring of all tax audits and review of Tax Risk Management in Blika tax platform
- giving additional advice for all taxes and administrative issues, cross-border issues, P.E. issues, VAT registrations in other countries etc.
- cross-border issues, examples: tax residence certificates, DTA application, filing for exemptions, permanent establishment issues, indirect taxation etc
- applying tax ruling or Advanced Pricing Agreement
- advice and review of tax due diligent works in M&A and reorganization; review tax clause or tax indemnity in S&P agreement
- tax planning or incentive opportunity
- providing Tax News with additional advise for taxes and administrative issues
providing tax sharing/training
The role encompasses a wide range of responsibilities, including but not limited to the following:
LATAM Business - Support business across all regions as and when necessary:
- review cross-border contracts and provide advice on wording of tax clause, delivery terms, invoicing, etc.
- review cross-border transactions with the client or between SGS affiliates (central billing) and provide advice on tax implications, in particular VAT, withholding tax and p.e. issues that may have an impact on the pricing
- provide alternative structures
- provide training on tax implications
- provide information on the Group Taxation Portal
- participate in conference calls with the client
Tax planning & legal reorganizations LATAM
- Re-Organization of legal entities within region, review valuations of operational companies, submission of tax rulings with tax authorities, review all legal documents, transfer investments
- Optimization and reduction of SGS legal entities
- Loan financing, capital measures, thin cap or interest barrier rules of LATAM countries/companies
- Assisting with set up of new legal entities or liquidation/closure of legal entities and branches
- On-going review of tax saving opportunities, tax credits, tax exemptions, etc. together with local Finance
Tax Compliance
- Regular review of Tax Risk Management / Tax Audit Risk followed by discussions with local Finance (in Blika Tax platform)
- Regular review and up-date of CIT Tax Rates, VAT rates, withholding tax rates and further information with regards to the region
Tax Accounting & Tax Reporting
- Assistance with completion of Form 18 for 5 quarterly reporting periods incl. HY, fast close and hard close Nov
- Quarterly review of tax reporting (Form 18) incl. detailed analysis of deferred tax, prior year adjustments, tax losses, effective vs. statutory tax rates, tax risks, etc. on a country-by-country basis
- Valuation allowances on deferred tax assets
- Prepare business forecasts for loss making companies
- Training in HFM form18 tax calculation
Projects - Support Corporate development in acquisition and divestment projects within the region
- Adjust legal or financing structure regarding any country especially optimization of legal structures
- Study new jurisprudence and tax legislation in the countries
- Review and optimization of intercompany transactions
- Tax review process in a number of countries in LATAM on an annual basis
- Implement necessary solutions for compliance and necessary changes to tax rules in Boss or indirect tax reporting
- Support Finance Transformation Team
- Identify process improvements and highlight to Transformation Team
- Advanced Pricing Agreement, mutual agreement procedure or the like (e.g. in Chile, Argentina, Brazil etc)
Cooperation with other functions
- Treasury; in particular inter-company loans and equity reconciliation
- Finance, in particular inter-company Corporate Funding Model invoices and follow up on receipt of payments
- Group Control, in particular Form 18 updates, Country by country reporting implementation and reconciliation Form
- Corporate Development – in particular look for tax efficient structure
- Legal – Re-Org and Global Contracts
- Internal Audit team – support to the Internal Audit team
- Local Finance organizations and regional controlling
- Legal – Business Support