Transfer Pricing and International Tax Manager

TaxPrime; Jakarta Pusat; Vor Ort; IDR 900.000.000 - 1.500.000.000; Vollzeit

Zusammenfassung

TaxPrime is seeking a Manager to lead day-to-day delivery of Transfer Pricing and international tax engagements in Jakarta. You will supervise a small team, guide fieldwork, and produce technically sound deliverables under senior sign-off.

You will drive Local/Master File and CbCR projects, manage CIT disclosures, and respond to TP audits. The role includes APA/MAP support, GMT/PSAK disclosures, and advisory work with clients on restructuring and intercompany policy design.

Qualifikationen

• Bachelor's degree in Accounting, Economics, Finance, Law, or related field; Master’s or Brevet C is advantageous.
• 5-7 years of transfer pricing or international tax experience, with leadership experience.
• Familiarity with PMK 172/2023, PMK 213/2016, PMK 15/2025, PMK 136/2024, and OECD TP Guidelines.

Aufgaben

• Lead TP documentation and compliance including Local/Master File and CbCR.
• Manage TP disclosures in CIT return and compliance calendar.
• Lead responses to TP audits and prepare position papers and defense files.
• Draft and manage objections/appeals letters in TP matters.
• Prepare unilateral and bilateral APA applications and MAP support.
• Assist GMT/QDMTT impact assessments and PSAK 46/IAS 12 disclosures.
• Advise on TP planning, restructurings, and intercompany policy design.
• Oversee engagement economics: scoping, budgeting, timelines, staffing.

Kenntnisse

Transfer pricing expertise

Leadership/management

Budgeting & staffing

Client-facing & stakeholder mgmt

English & Bahasa Indonesia proficiency

Analytical skills

Time management

Ausbildung

Bachelor's degree in Accounting/Economics/Finance/Law

Master's degree or Brevet C advantageous

Tools

Bloomberg

Orbis

Capital IQ

Jobbeschreibung

JOB DESCRIPTION

The Manager owns the day-to-day delivery of Transfer Pricing and international tax engagements: leading fieldwork, producing technically sound deliverables, and supervising a small team, while working under a Senior Manager or Partner for client strategy and sign-off.

TRANSFER PRICING DOCUMENTATION AND COMPLIANCE

• Lead the preparation and review of Local File, Master File and CbCR (PMK 213/PMK.04/2016), applying ex-ante arm's-length analysis.
• Run functional, industry and economic (CUP/TNMM/CPM/DEMPE) analyses and benchmarking studies, and review the work of Senior Associates and/ or Associates.
• Manage TP disclosures in the annual CIT return and related compliance calendar for a client portfolio.

TRANSFER PRICING AUDIT, OBJECTION AND APPEAL

• Lead client responses to DGT Transfer Pricing audit queries and formal tax audits (including under PMK 15/2025 timelines), preparing position papers and defense files.
• Draft and manage objection letters and appeal submissions (Tax Court) on Transfer Pricing adjustments, coordinating with legal counsel where needed.
• Represent the engagement team in meetings with tax auditors and objection or appeal reviewers.

APA AND MAP

• Prepare unilateral and bilateral APA applications and supporting economic analysis; manage the APA negotiation timeline with the DGT.
• Support MAP requests and case files for treaty-based double taxation relief, coordinating with the Competent Authority process.

GMT (PILLAR TWO)

• Assist clients with GMT/QDMTT impact assessments and GloBE income computations under PMK 136/2024, including ETR modelling and top-up tax calculations.
• Support GIR/DMTT/ UTPR return preparation and coordination with clients' accounting teams on PSAK 46/IAS 12 disclosures.

ADVISORY AND ENGAGEMENT MANAGEMENT

• Advise clients on Transfer Pricing planning, business restructuring and intercompany policy design to maintain arm's-length positions.
• Manage engagement economics: scoping, budgeting, timelines, and staffing across concurrent engagements.
• Coach, train, and review the work of Associates and/ or Senior Associates; contribute to proposals and technical training materials.

JOB REQUIREMENTS

• Bachelor's degree in Accounting, Economics, Finance, Law, or a related field; a Master's degree or Brevet C is an advantage.
• 5-7 years of relevant experience in transfer pricing or international tax, with a significant portion in a Big 4 or reputable tax advisory firm, or the DGT's Transfer Pricing function, and have minimum 3 years experience in a managerial position.
• Working knowledge of PMK 172/2023 (Transfer Pricing), PMK 213/2016 (Transfer Pricing documentation/CbCR), PMK 15/2025 (tax audit), PMK 136/2024 (GMT), and the OECD Transfer Pricing Guidelines.

• Demonstrated experience across at least two of: Transfer Pricing documentation, Transfer Pricing audit defense, objection/appeal, APA, or MAP.
• Strong economic or financial analysis skills (CUP, TNMM, CPM, DEMPE, benchmarking databases such as Bloomberg/Orbis/Capital IQ).
• Proven ability to manage multiple engagements concurrently, including budgeting, timelines, and staffing.
• Experience supervising, reviewing, and developing junior staff (Associate or Senior Associate level).
• Strong written and verbal communication in both Bahasa Indonesia (formal legal register) and English, including drafting objection or appeal letters and client-facing reports.
• Strong client-facing and stakeholder-management skills, including representing clients before tax auditors and reviewers.
• Exposure to industries with active Transfer Pricing scrutiny (extractive industries, financial services, manufacturing) is an advantage.