Manager - Direct Tax & Transfer Pricing - 4 - 9 yrs

Location: Begur, Electronic City, Bangalore (On-site)

Experience: 4-5 years post-qualification (mix of consulting and industry preferred), with strong Transfer Pricing expertise; global/international tax exposure is an added advantage

Qualification: Chartered Accountant (CA) - Mandatory

Role Overview

We are seeking a Chartered Accountant with 4-5 years of experience across Direct Tax and Transfer Pricing to own and drive our DT and TP agenda. The ideal candidate combines Big 4/consulting rigour with hands-on industry execution, and can independently manage compliance, litigation, intercompany arrangements, and cross-border tax matters as Ultrahuman scales across international markets.

Key Responsibilities

Transfer Pricing

- Design, implement, and monitor the group's transfer pricing policies for intercompany transactions (goods, services, royalties, cost allocations, financing).

- Manage TP documentation - Local File, Master File, Form 3CEB, and CbCR compliance across jurisdictions.

- Conduct/review benchmarking studies and functional analyses; manage external TP advisors.

- Handle TP assessments, audits, and litigation; evaluate APA/safe harbour options where relevant.

- Review and structure intercompany agreements in coordination with legal and finance teams.

Direct Tax

- Own corporate tax compliance - returns, advance tax, tax provisioning (including deferred tax), and tax audit.

- Manage assessments, appeals, and litigation strategy for income-tax matters.

- Advise on withholding tax on domestic and cross-border payments, including treaty (DTAA) analysis.

- Support international tax matters - permanent establishment risk, POEM, BEPS/Pillar Two developments, and structuring of overseas operations.

Leadership & Business Partnering

- Act as tax business partner to leadership on new markets, business models, and product launches.

- Build and improve tax processes, controls, and automation; mentor junior tax team members.

- Manage relationships with tax authorities, Big 4 advisors, and auditors.

Candidate Profile

- Qualified Chartered Accountant (CA) - mandatory.

- 4-5 years of post-qualification experience in Direct Tax and Transfer Pricing, ideally a blend of consulting (Big 4/leading firm) and industry.

- Demonstrably strong Transfer Pricing expertise - documentation, benchmarking, litigation, and policy design.

- Exposure to global/cross-border tax matters (multi-jurisdiction TP, DTAA, international structuring) is a strong advantage.

- Strong analytical, drafting, and stakeholder management skills; ability to operate independently in a fast-paced environment.