Senior Manager – Transfer Pricing – CA

Key Responsibilities:

Client Delivery & Engagement Management:

– Lead end-to-end delivery of transfer pricing engagements including documentation, benchmarking studies, and compliance filings under the Indian Income Tax Act, 1961 and relevant OECD/UN guidelines.

– Prepare and review Transfer Pricing Study Reports (Form 3CEB and contemporaneous documentation) for Indian and multinational clients.

– Advise clients on structuring intercompany transactions (services, goods, IP, loans, guarantees, cost-sharing arrangements) in a tax-efficient and arm’s length compliant manner.

– Manage transfer pricing assessments, respond to notices from the Assessing Officer / Transfer Pricing Officer (TPO), and coordinate with clients during audit proceedings.

– Represent clients before the TPO, Dispute Resolution Panel (DRP), Income Tax Appellate Tribunal (ITAT), and assist in High Court/Supreme Court matters in coordination with senior counsel.

– Assist clients in Advance Pricing Agreement (APA) negotiations – unilateral, bilateral, and multilateral – and support rollback proceedings.

– Advise on BEPS-related issues including Country-by-Country Reporting (CbCR), Master File, and Local File compliance.

– Manage Safe Harbour Rule analysis and applications for eligible taxpayers.

– Provide value chain analysis and global operating model advisory for restructuring engagements.

Technical & Advisory:

– Conduct economic and functional analysis (FAR) for complex intercompany arrangements.

– Carry out database searches and benchmarking using Prowess, Capitaline, Bureau van Dijk (BvD), and other commercial databases.

– Advise on cross-border related party transactions across sectors including IT/ITES, pharmaceuticals, manufacturing, financial services, and e-commerce.

– Stay abreast of developments in Indian and international transfer pricing jurisprudence, CBDT circulars, notifications, and OECD/G20 BEPS updates.

– Identify planning opportunities and risk areas for clients proactively.

Team Leadership & Development:

– Lead and mentor a team of Associates, Senior Associates, and Assistant Managers.

– Review work products for technical accuracy, completeness, and client-ready quality.

– Allocate and manage team resources across concurrent engagements.

– Conduct periodic performance reviews and provide constructive developmental feedback.

– Facilitate internal knowledge-sharing sessions and technical training for the team.

Business Development & Client Relationships:

– Develop and maintain strong relationships with existing clients, acting as a trusted advisor.

– Identify cross-selling opportunities across the firm’s service lines (direct tax, indirect tax, M&A, regulatory).

– Contribute to preparing proposals, presentations, and thought leadership content.

– Assist Partners in pitching for new client mandates.

Eligibility Criteria:

– Qualification: Chartered Accountant (ACA/FCA) from ICAI

– Post-Qualification Experience: 8 – 10 years, with at least 6 – 7 years in Transfer Pricing

– Experience Setting: Big 4 / mid-size CA firm / in-house MNC TP team (CA firm experience preferred)

– Industry Exposure: Broad sector exposure; IT/ITES, pharma, or manufacturing preferred

– Litigation Experience: Hands-on experience with TPO proceedings, DRP, and ITAT

– APA Experience: Desirable

Skills & Competencies:

Technical Skills:

– Deep knowledge of Indian transfer pricing regulations (Sections 92 – 92F of the Income Tax Act, 1961 and Rules 10A – 10THD of the Income Tax Rules, 1962)

– Proficiency in OECD Transfer Pricing Guidelines and BEPS Action Plans (particularly Actions 8 – 10, 13, 15)

– Strong command over benchmarking methodologies (CUP, RPM, CPM, TNMM, Profit Split)

– Working knowledge of commercial databases (Prowess, Capitaline, BvD/Orbis, RoyaltyStat, ktMINE)

– Familiarity with global tax treaty networks and their interaction with transfer pricing