Transfer Pricing and International Tax, Senior Tax Manager

Fluence is the leading global energy storage technology and services company, created and backed by Siemens and AES, two industry powerhouses and pioneers in energy storage. Fluence unites the scale, experience, breadth, and financial backing of the two most experienced icons in energy storage.

Our mission is to create a more sustainable future by transforming the way we power our world. Energy storage is critical to this transformation, yet today the market is fragmented and customers face the challenge of finding a trusted technology partner amidst conflicting technical claims, inexperienced vendors and installers, and new market entrants with limited power sector knowledge.

Fluence brings the proven technology solutions and services that overcome the commercial and regulatory barriers that stand in the way of modernizing our energy networks. We are the partner that can deliver at a global scale with the most experienced and knowledgeable team in the world.

About Fluence: Fluence Energy, Inc. (Nasdaq: FLNC) is a global market leader in energy storage products and services, and optimization software for renewables and storage. With a presence in over 47 markets globally, Fluence provides an ecosystem of offerings to drive the clean energy transition, including modular, scalable energy storage products, comprehensive service offerings, and the Fluence IQ Platform, which delivers AI-enabled SaaS products for managing and optimizing renewables and storage from any provider. Fluence is transforming the way we power our world by helping customers create more resilient and sustainable electric grids.

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We are guided by our passion to transform the way we power our world. Achieving our goals requires creativity, diversity of ideas and backgrounds, and building trust to effect change and move with speed.

Fluence currently has thousands of MW of energy storage projects operated or awarded worldwide in addition to the thousands of MW of projects managed by our trading platform—and we are growing every day.

Fluence is defined by its unwavering commitment to safety, quality, and integrity.

We achieve our goals and meet our customer’s needs by cultivating curiosity, adaptability, and self-reflection in our teams.

We value the diversity in thought and experience of our coworkers and customers. Through honest, forthcoming, and respectful communications we work to ensure that Fluence is an inclusive and welcoming environment for all. 

We are seeking an experienced and highly motivated Transfer Pricing and International Senior Tax Manager to join our Corporate Tax team. In this role, you will play a crucial part in managing our transfer pricing strategies and work closely with international tax and other key stakeholders to optimize our company's global tax position. The ideal candidate will have a strong background in Transfer Pricing, hands-on experience in International Tax and will be responsible for managing day-to-day aspects of intercompany and international taxation and transfer pricing functions. Reporting directly to the Director of International Tax, with oversight from the Global Tax Lead / Director of Transfer Pricing, your key responsibilities include:

Key Responsibilities:

1.International Tax and Transfer Pricing Planning: 

•Stay current with changes in international tax laws and transfer pricing regulations, advising on potential impacts and opportunities.

•Assist the Global Tax Lead / Director of Transfer Pricing in developing and implementing international tax strategies and transfer pricing policies to optimize our global tax position while ensuring compliance with applicable laws and regulations.

•Act as a technical resource to aid in planning for rapid global expansion as well as evolving tax regulation changes (e.g., Pillar 2, public CBCR, etc.).

•Provide guidance and support on transfer pricing matters related to intercompany transactions, including intellectual property, services, and goods.

2.International Tax and Transfer Pricing Provision and SOX:

•Oversee the US international tax calculation for annual tax provision purposes, including Subpart F, GILTI, FDII, and BEAT.

•Assist in the preparation and review of transfer pricing calculations for annual tax provisions, including inclusion of intercompany transactions into entity level results. 

•Manage the overall execution of internal controls and SOX compliance for International and Transfer Pricing tax functions and communicate with external auditors.

3.International Tax Compliance: 

•Manage external advisors and assist the Director of International Tax in the preparation and review international components of tax compliance including but not limited to Subpart F, GILTI, FDII, BEAT, and E&P. 

•Manage external advisors in the preparation of US international forms and the timely execution of the relevant tax filings, including Forms 5471, 5472, and 8858

•Experience with Permanent Establishments and Statutory Financials is a plus.

4.Transfer Pricing Compliance:

•Review transfer pricing documentation to ensure adherence to local and international tax regulations.

•Manage external advisors to maintain contemporaneous global compliance and provide timely tested party data for external compliance preparation, including Master File, Local Files, CBCR, and local tax form filings (e.g., US F5471/2 8858, 8975, Australia IRPT, India 3CEB, Chile F1907, etc.).

5.Transfer Pricing Controversy:

•Participate in international tax and transfer pricing audits and examinations, working closely with tax authorities to resolve issues and provide necessary documentation. This role provides an opportunity to be the integral leader for bilateral APA.

6.Transfer Pricing Implementation: 

Collaborate with cross-functional teams to ensure consistency in global transfer pricing policies and strategies while acting as a technical resource and point of contact for various key business stakeholders, including:

•Business operations – coordinate with stakeholders to plan and implement transfer pricing policies for new entities, new transactions, or other relevant intercompany policies.

•Legal – Assist in the development and execution of intercompany agreements and transfer pricing policies for new transactions and business developments.

•Accounting – work with Senior Manager of Intercompany Accounting to ensure pre-close entries are in line with transfer pricing policy (i.e., no book/tax differences for transfer pricing entries).

•Tax – work with the team to ensure coordination on various tax implications affected by intercompany and transfer pricing, such as withholding tax, VAT, customs, duties, etc.

•Treasury – work with the team to ensure intercompany settlements follow transfer pricing policies, as well as any other intercompany funding implications such as loans, guarantees, or equity contributions.

•FP&A – coordinate with stakeholders for intercompany allocations and other cost accounting implications for budgeting and actuals.

•Financial Controllers – update stakeholders on intercompany positions and transactions impacting both management books as well as GAAP and statutory.