Transfer Pricing Group Specialist: Bryanston at Coca-Cola

Coca-Cola Beverages Africa (CCBA) presents an exciting opportunity for a Transfer Pricing Specialist, to join the finance team at CCBA. The role will report to the Group Lead: International Tax and Transfer Pricing.

CCBA is the 8^th largest Coca-Cola bottling partner in the world by revenue, and the largest on the continent. It accounts for over 40% of all Coca-Cola products sold in Africa by volume. With over 18 000 employees in Africa, CCBA services more than 735 000 customers with a host of international and local brands. CCBA operates in 15 countries, including its six key markets of South Africa, Kenya, Ethiopia, Uganda, Mozambique and Namibia, as well as Tanzania, Botswana, Ghana, Zambia, the islands of Comoros and Mayotte, Eswatini, Lesotho, and Malawi.

The Transfer Pricing (TP) Specialist’s responsibilities will include to:

• Monitor international (e.g., OECD) and local transfer pricing developments proactively.
• Prepare and maintain globally consistent transfer pricing documentation for the CCBA Group across 15 markets.
• Ensure accurate treatment of intra-group transactions and perform financial analyses as needed.
• Coordinate and complete required transfer pricing forms, including Country-by-Country notifications and Pillar-Two regulatory filings.
• Manage transfer pricing formalities and ensure group policies, guidelines, and directives are commercially aligned and audit defensible.
• Support tax audits and respond to inquiries from tax authorities as required.

Key Duties & Responsibilities

• Architect and operationalise a sustainable internal documentation function, including talent planning, systems integration, and process design, to reduce external reliance and improve cost-effectiveness.
• Lead the end-to-end transition of transfer pricing documentation from external Big 4 advisors to an in-house function, establishing robust governance and scalable processes aligned with global best practices.
• Assume pan-African responsibility for the timely and accurate preparation of Local Files and Master File, ensuring alignment with Organisation for Economic Co-Operation and Development (OECD) guidelines and local regulatory requirements.
• Provide strategic input on pricing models for intercompany goods, services, and financing arrangements, balancing commercial objectives with tax compliance.
• Support CCBA markets in all the 15 countries on implementation of Group’s pricing policies and guidelines that are commercially aligned and audit-defensible across all transaction.
• Proactively via the monitoring mechanisms to identify changes in local and global TP regulations and manage associated risks through timely policy and process updates.
• Act as the senior liaison between finance, tax, legal, treasury, and commercial teams to embed TP policy within business processes and drive enterprise-wide alignment.
• Support TP audit response, ensuring defensible documentation, managing advisor engagement where necessary, and aligning positions across jurisdictions.
• Drive technical training, documentation quality standards, and continuous process improvement.
• Select, implement, and scale documentation and compliance tools (e.g., TP software, data analytics platforms) to increase efficiency, transparency, and control.
• Drive the overall program to internalise documentation, including change management, KPI tracking, and reporting to executive stakeholders on progress, impact, and value delivery.

Skills, Experience & Education

Qualifications:

• Bachelor's degree in Accounting, Tax, Economics, or a related field.
• Chartered Accountant CA(SA) or MCom (Taxation) or HDip (Taxation) equivalent is preferred.

Experience:

• Minimum of 5+ years’ post qualification experience in Taxation, with at least 3+ years focused on Transfer Pricing.
• Demonstrated experience in preparing or reviewing TP documentation in line with OECD and Base Erosion and Profit Shifting requirements.
• Prior Big 4 consulting experience and/or in-house experience at a multinational enterprise strongly preferred.
• Proven track record of managing or transitioning TP compliance processes internally.
• Exposure to cross-border intercompany pricing, audits, and controversy management is a plus.

Skills:

• Deep expertise in OECD guidelines, BEPS, local TP regulations and international taxation.
• Proven experience bringing TP documentation in-house from Big 4 advisors.
• Strong knowledge of Local File, Master File, and Country-by-Country Reporting requirements.
• Ability to design and implement intercompany pricing policies.
• Skilled in managing audits and TP controversy matters.
• Familiarity with TP software/tools (e.g., ONESOURCE, TP Catalyst)
• Strong verbal interacting with various stakeholders and excellent written communication and documentation drafting skills.
• Problem-solving ability with a commercial mindset.
• Strong project leadership and stakeholder management.
• Flexibility to adapt to changing business and stakeholder priorities
• Ability to analyse huge financial data to support strategic decisions.
• Critical thinking to resolve commercial issues and improve Transfer Pricing processes.