Senior Associate/Senior Manager – Transfer Pricing – CA

Key Responsibilities:

Transfer Pricing Compliance & Documentation

– Prepare and review Transfer Pricing documentation including Local File, Master File, Form 3CEB, and contemporaneous documentation.

– Conduct benchmarking studies, FAR analysis, and economic analysis using relevant commercial databases.

– Work on inter-company transaction analysis and ensure compliance with Indian Transfer Pricing regulations and OECD Guidelines.

– Support BEPS-related compliance including Country-by-Country Reporting (CbCR), Master File, and Local File requirements.

– Assist clients in maintaining robust transfer pricing documentation and compliance frameworks.

Litigation, Assessments & APA Support:

– Handle transfer pricing assessments, audits, notices, and litigation proceedings before TPO, DRP, ITAT, and other authorities.

– Prepare submissions, technical responses, and supporting documentation for assessment proceedings.

– Support Advance Pricing Agreement (APA) assignments including unilateral, bilateral, and multilateral APA engagements.

– Coordinate with clients and senior counsel for litigation and dispute resolution matters.

Advisory & Technical Research:

– Conduct technical research on transfer pricing and international taxation matters.

– Advise clients on cross-border related party transactions, restructuring, operating models, and inter-company arrangements.

– Assist in drafting advisory notes, technical memorandums, and client presentations.

– Evaluate transfer pricing methodologies including CUP, RPM, CPM, TNMM, and Profit Split Method.

– Identify tax planning opportunities and proactively assess transfer pricing risks.

Client Management & Execution:

– Coordinate with clients for financial data, business information, and documentation requirements.

– Ensure timely execution of assignments while maintaining high-quality deliverables.

– Participate in client discussions and engagement management activities.

– Build and maintain strong client relationships and act as a trusted advisor.

Team Management & Leadership:

– Lead and mentor Associates, Senior Associates, Assistant Managers, and junior team members.

– Review work products for technical accuracy and quality standards.

– Allocate resources effectively across multiple concurrent engagements.

– Conduct technical training sessions and contribute to internal knowledge-sharing initiatives.

Eligibility Criteria:

For Senior Associate:

– CA / MBA (Finance) / relevant qualification in Finance, Economics, or related fields

– 34 years of experience in Transfer Pricing

– Strong exposure to Indian Transfer Pricing regulations and compliance

– Experience in benchmarking studies and transfer pricing documentation

For Senior Manager:

– Chartered Accountant (ACA/FCA) from ICAI

– 810 years of post-qualification experience with at least 67 years in Transfer Pricing

– Experience in Big 4, reputed CA firms, or multinational transfer pricing teams preferred

– Hands-on exposure to litigation, TPO proceedings, DRP, ITAT, and APA assignments