KEY RESPONSIBILITIES:

Transfer Pricing Advisory

- Lead transfer pricing advisory assignments for multinational and domestic clients.

- Advise on transfer pricing policies involving intercompany services, management charges, royalties, distribution arrangements, and business restructuring transactions.

- Work on transfer pricing issues relating to intangibles, DEMPE analysis, value creation, and ownership of intellectual property.

- Support clients on complex transfer pricing models, including practical exposure to Profit Split Method and other non-routine transfer pricing issues.

- Advise clients on brand royalty arrangements, AMP-related matters, and transfer pricing implications of business expansion or restructuring.

- Assist clients in designing and implementing practical transfer pricing frameworks aligned with business operations.

Documentation & Global Compliance

- Review and oversee transfer pricing documentation, benchmarking studies, and economic analyses.

- Lead global and regional transfer pricing documentation projects, including coordination with overseas stakeholders and network firms.

- Manage Master File and other global transfer pricing reporting requirements.

- Ensure quality, consistency, and timely delivery of client engagements.

Litigation & Controversy

- Manage transfer pricing audits, assessments, and dispute resolution matters.

- Lead preparation of submissions, responses, technical positions, and litigation support documentation.

- Support representation before tax authorities and appellate forums.

- Work on APA, MAP, and other dispute resolution mechanisms.

- Develop practical defence strategies for transfer pricing adjustments and controversy matters.

Related Party Transactions & Regulatory Support

- Advise clients on transfer pricing aspects of related party transactions.

- Support assignments involving SEBI LODR requirements relating to Related Party Transactions (RPTs).

- Coordinate with corporate and regulatory teams on transaction reviews and documentation requirements.

Client Relationship Management

- Act as a relationship manager for key client accounts.

- Deliver commercially practical and technically robust solutions.

- Identify opportunities for expanding existing client relationships.

- Work closely with senior management teams, CFOs, tax leaders, and business stakeholders.

Practice Development & Leadership

- Support business development initiatives, proposals, and client pitches.

- Contribute to thought leadership, technical publications, and client seminars.

- Mentor and develop Managers, Assistant Managers, and Associates.

- Review engagement quality and drive technical excellence across the team.

QUALIFICATIONS & EXPERIENCE

Educational Background

- Chartered Accountant (ICAI) - Mandatory.

- Additional qualifications such as LLB, ADIT, or equivalent certifications will be an advantage.

Professional Experience

- 8-10 years of post-qualification experience in Transfer Pricing.

- Prior experience with a Big 4 or leading consulting/advisory firm preferred.

- Experience managing client engagements independently and leading teams.

- Demonstrated exposure to advisory, litigation, and documentation assignments.

- Experience working with multinational clients and global transfer pricing projects.

TECHNICAL SKILLS:

The candidate should possess strong practical experience in:

- Transfer pricing advisory and planning.

- Transfer pricing documentation and benchmarking.

- Transfer pricing litigation and controversy management.

- Brand royalties, DEMPE analysis and intellectual property-related arrangements.

- Management charges and intra-group service transactions.

- AMP-related transfer pricing issues.

- Profit Split Method and complex transfer pricing models.

- APA and MAP engagements.

- Global transfer pricing documentation projects.

- SEBI LODR related party transaction engagements.

PERSONAL ATTRIBUTES:

- Strong client management and stakeholder engagement skills.

- Commercially oriented with a practical problem-solving approach.

- Strong communication and presentation capabilities.

- Ability to manage multiple engagements and teams simultaneously.

- Leadership mindset with a focus on people development and collaboration.

WHAT WE OFFER:

- Leadership role within a growing and high-quality Transfer Pricing practice.

- Direct interaction with leading multinational and Indian business groups.

- Opportunity to work on complex advisory, controversy, and strategic assignments.

- Collaborative and entrepreneurial work environment.

- Competitive compensation and long-term career progression opportunities.

- Clear pathway towards broader leadership responsibilities within the firm.