The team

Currently the ASML Tax & Customs Team includes close to 50 tax and customs professionals residing in the Netherlands based HQ and in the multiple regional/local offices in APAC and the US. The Tax & Customs team includes regional teams (NL/EMEA, Asia and US) and global expertise teams (Indirect tax, Customs, Transfer Pricing, Wage Tax and PMO). ASML’s Tax & Customs team is accountable for the Tax and Customs affairs in all jurisdictions where ASML operates.

The flat ASML organization and X-sector approach for addressing business challenges allows the Tax & Customs team to closely interact with the company operations. The Tax & Customs team provides expertise guidance to the business and manages tax/customs risks according to its global strategy approved by ASML Board of Management. In this respect the Tax & Customs team closely collaborates with the other Finance, Legal and Operations teams to ensure appropriate and efficient execution in practice.

ASML’s Global Transfer Pricing Team is worldwide accountable for all transfer pricing matters and reports to ASML Tax. Transfer pricing compliancy is supported by Finance. The Global Transfer Pricing Team closely interact with the company operations, manage tax risks and provide for tax planning ideas according to the global Tax Strategy and underlying global Transfer Pricing Policy. Having entered into many unilateral and bilateral advance pricing agreement procedures with Netherlands and foreign tax authorities, ASML Tax has successfully worked on obtaining certainty on its transfer pricing positions and enhancing relationships with local tax authorities. New developments such as BEPS Pillar 1 and 2 are closely monitored and acted upon when needed.

The Global Transfer Pricing Team is expanding and we are looking for an seasoned Transfer Pricing expert to focus on Korea and Rest of Asia (RoA) Transfer Pricing matters. The Transfer Pricing Manager will be a member of the Transfer Pricing team consisting currently of 4 Transfer Pricing professionals (located in NL, China and the US).

Job Mission

The job mission of the Transfer Pricing Manager Korea and RoA is to contribute to and implement the Transfer Pricing strategy while pro-actively supporting ASML and its business partners in the mentioned jurisdictions.

Context of the position

The Manager Transfer Pricing Korea and RoA will report to the Global Head of Transfer Pricing based in the Netherlands, and will work together with the other members of Global Transfer Pricing Team on various transfer pricing related topics and projects from a strategical and tactical point of view while focusing on the Korea and the RoA including Malaysia, Japan and Singapore.

The job will require internal interfaces with all ASML departments and Senior Management and external interfaces with outside counsel and consultants, tax authorities and other (governmental) institutions. When being part of ASML Tax, you’ll face demanding challenges and enjoy the freedom to operate and do what is good for the company.

This position will be located in the Korea Head office in Hwaseong with options to work in our dependance office in Gangnam. Although the reporting line is towards the Netherlands, you will be surrounded by the local Tax & Customs team. 

Job Description

Contribute and ensure adherence to the regional policies for the Korean and RoA region, seamlessly connecting to the Global Tax Strategy and the underlying Global Transfer Pricing Policy for the ASML Group;

Provide efficient transfer pricing advice to a variety of stakeholders based on expected future developments, including advice on cross border transactions and merger and acquisitions;

Participate in cross sector projects as representative of the Global Transfer Pricing team;

Ensure the management of various Korean and RoA projects and possibly global transfer pricing projects and outside consultants (such as advance pricing agreements procedures);

Monitor and enhance the transfer pricing control framework for the Korean and RoA region;

Manage Transfer Pricing audits and Transfer Pricing exposures (in both transfer pricing specific audits and regular tax audit) in Korea and RoA;

Participate in the quarterly tax accounting process for determination of transfer pricing positions in Korea and RoA (US GAAP Tax Provision);

Review group structure and investments in light of changing international transfer pricing regulations (e.g. OECD Transfer Pricing Guidelines and BEPS) and local legislations in Korean and RoA countries;

Contribute to the further enhancement and implementation of our tax technology strategy.

Personal skills

Team player with a flexible & pro-active attitude

Strong drive with a hands-on, structured, accurate and result oriented working style.

Being a self-starter and ability to progress independently whilst showing ownership of issues from start to finalization

A strategic mindset while having the ability to translate strategy into actionable objectives (short, medium and long-term).

Strong analytical skills, with the ability to translate complex business issues into simple problem statements, clear processes and actions.

Understanding of complex concepts and models, making the connection between managerial reporting and tax or transfer pricing impact

A communicative personality who is able to act as a professional business partner and adapt to his/her audience and able to translate complex transfer pricing topics into layman language.

Able to build relationships and achieve results with other functional areas.

Able to cope with a multicultural, dynamic and changing environment. Experience with Asian and European cultures is a pre

Good time management skills and able to manage towards tight deadlines.

Interest in AI, tax technology and other means to develop error-prone processes and analyses. 

Native in Korean and Fluent in English, both oral and written.

Education

Academic reputed Economic/Business Tax degree or the equivalent

CPA license holder in Korea is preferred

Keen interest in developing and maintaining tax technical knowledge, also outside the TP domain.

Experience

Minimum of 10 years’ working experience in international taxation preferably as an in-house transfer pricing counsel (pre) or within a big four environment.

Excellent understanding of the international (OECD) transfer pricing regulations and practiced in Korean and RoA countries.

More than average experience in managing dynamics and impact of transfer pricing solutions to corporate income tax and indirect tax areas.

Experience with transfer pricing implications of designing and implementation of (changes in) a new operating model within a multinational company.

Understanding of tax accounting principles.

 Approximately 10% of working time will be required for travel.

ASML is an Equal Opportunity Employer that values and respects the importance of a diverse and inclusive workforce. It is the policy of the company to recruit, hire, train and promote persons in all job titles without regard to race, color, religion, sex, age, national origin, veteran status, disability, sexual orientation, or gender identity. We recognize that diversity and inclusion is a driving force in the success of our company.

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