Senior Manager - Transfer Pricing - CA

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.