Employment Type: Full-time

Job Summary:

- We are seeking a highly specialized and technically proficient Transfer Pricing Specialist to manage all aspects of the company's intercompany pricing policies and compliance.

- The ideal candidate will have 3-8 years of experience with a strong foundation in economic analysis, proficiency with global transfer pricing databases, and a proven track record of preparing robust documentation compliant with OECD and local tax regulations.

- This role is crucial for ensuring the Arm's Length Principle is consistently applied across all cross-border transactions.

Key Responsibilities and Technical Focus:

Policy Development and Strategy:

- Develop, implement, and continuously monitor group-wide transfer pricing policies and strategies designed to align with business objectives while minimizing tax risk and ensuring compliance with the Arm's Length Principle.

- Provide expert guidance on the appropriate selection and application of various transfer pricing methods ( CUP, Resale Price, Cost Plus, Transactional Net Margin Method - TNMM).

- Conduct in-depth functional analysis and economic analysis to accurately delineate intercompany transactions, identifying functions performed, assets employed, and risks assumed by each entity.

Documentation and Compliance:

- Lead the preparation and finalization of detailed, high-quality Transfer Pricing Documentation for all entities, including the Local File, Master File, and ensuring accurate data input for Country-by-Country Reporting (CbCR).

- Perform rigorous comparability analyses, utilizing professional databases such as TP Catalyst, Orbis, or comparable tools to select independent comparable companies, financial data, and establish arm's length ranges.

- Ensure strict compliance with OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, coupled with adherence to specific local tax laws and regulations in India and relevant foreign jurisdictions.

Transaction Evaluation and Risk Management:

- Critically evaluate and document all intercompany transactions, focusing on complexity areas such as the transfer of intangible assets (IP, trademarks), intercompany services (management, technical support), and financing arrangements (loans, guarantees).

- Provide technical guidance and support in pricing new or restructured intercompany agreements, ensuring terms and conditions are aligned with the transfer pricing policy and economic reality.

- Assist in the preparation of applications and documentation for Advance Pricing Agreements (APAs) or Mutual Agreement Procedures (MAPs) to secure future certainty on intercompany pricing.

Audit Support and Regulatory Monitoring:

- Act as a key resource in supporting internal and external tax audits, specifically focusing on responding to transfer pricing-related inquiries and assessment proceedings from the Income Tax Department and other tax authorities.

- Maintain a structured monitoring system to analyze changes in global and local transfer pricing regulations ( BEPS actions, permanent establishment developments) and promptly assess their financial and operational impact on the organization.

Collaboration and Stakeholder Management:

- Collaborate effectively with Finance and Accounting teams to ensure consistency between transfer prices, transactional accounting, and customs valuation data.

- Work closely with the Legal team to draft and review intercompany legal agreements that accurately reflect the functional analysis and pricing policy.

Preferred Skills:

- A professional qualification such as a CFA, CA (Chartered Accountant), CPA, or equivalent advanced degree (Master's in Economics/Finance) is highly preferred.

- Proven advanced technical proficiency in using and managing data within global transfer pricing databases (TP Catalyst, Orbis, RoyaltyStat) and financial data platforms.

- In-depth practical experience dealing with Indian Transfer Pricing regulations (Rule 10B, specified domestic transactions) and successfully handling scrutiny/appeal proceedings.

- Strong background in financial modeling and complex data analysis using Excel and/or specialized statistical software.

- Excellent technical drafting skills for preparing high-quality transfer pricing documentation and defense files