Senior Manager Transfer Pricing Controversy

At Bayer we're visionaries, driven to solve the world's toughest challenges and striving for a world where ,Health for all, Hunger for none' is no longer a dream, but a real possibility. We're doing it with energy, curiosity and sheer dedication, always learning from unique perspectives of those around us, expanding our thinking, growing our capabilities and redefining 'impossible'. There are so many reasons to join us. If you're hungry to build a varied and meaningful career in a community of brilliant and diverse minds to make a real difference, there's only one choice.
Senior Manager Transfer Pricing Controversy (m/f/d)
Your Tasks And Responsibilities

• Co-lead Bayer's global and German transfer pricing controversy strategy, ensuring alignment across business units and jurisdictions and support mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA), including negotiation strategy and documentation
• Manage and support international tax audits by providing transfer pricing data, documentation, and strategic input aligned with Bayer's global tax positions
• Develop and implement data analytics and visualization solutions to support controversy cases and strategic decision-making
• Collaborate with business modelling/partnering teams to ensure readiness and consistency in controversy scenarios
• Support public reporting requirements (e.g., CbCR, OECD Pillar I) with robust data and narrative frameworks
• Facilitate retrospectives and learning loops post-audit or controversy resolution to improve future readiness
• Lead cross-functional initiatives to embed controversy readiness into business model design and tax governance
• Coach junior team members and foster a culture of transparency, agility, and continuous learning
• Represent Bayer in external forums and with tax authorities, maintaining integrity and strategic positioning

Who You Are

• Tax specialist with university (of applied sciences) degree in tax Education & Certifications
• Degree in Economics, Business Administration, Tax, or Law, preferred Certified German Tax Advisor (StB), Chartered Financial Analyst (CFA), or equivalent Experience & Capabilities
• Extensive experience in transfer pricing, with proven experience in controversy management, MAP/APA processes
• Strong understanding of international and German TP regulations and audit practices
• Demonstrated ability to lead complex, cross-border tax projects and defend positions under scrutiny Technical Skills
• Proficiency in data analytics tools (PowerBI, Tableau, Alteryx, Knime) as well as familiarity with ERP systems (SAP), tax engines, and documentation platforms
• Coaching mindset and ability to lead through ambiguity
• Familiarity with skills frameworks and capability-based development
• Fluent in English and German preferred

YOUR APPLICATION
This is your opportunity to tackle the world's biggest challenges with us: Maintaining our health, feeding growing populations and slowing the rate of climate change. You have a voice, ideas and perspectives and we want to hear them. Because our success begins with you. Be part of something big. Be Bayer.

Bayer welcomes applications from all individuals, regardless of race, national origin, gender, age, physical characteristics, social origin, disability, union membership, religion, family status, pregnancy, sexual orientation, gender identity, gender expression or any unlawful criterion under applicable law. We are committed to treating all applicants fairly and avoiding discrimination.

Location:
Germany : North Rhine Westfalia : Leverkusen

Division:
Enabling Functions

Reference Code:
857305