Transfer Pricing & International Tax Manager

TaxPrime; Jakarta Pusat; Presencial; IDR 350 000 000 - 580 000 000; Tempo integral

Resumo da oferta

TaxPrime is seeking a Manager to own day-to-day transfer pricing and international tax engagements, leading fieldwork, delivering technically sound work, and supervising a small team under a Senior Manager/Partner.

The role covers TP documentation, audits, APA/MAP, GMT (Pillar Two) and advisory work, coordinating with clients and accounting teams to maintain arm’s-length positions and compliant processes.

Responsabilidades

• Lead day-to-day delivery of TP and international tax engagements, supervising a small team.
• Perform fieldwork, produce deliverables, and seek timely sign-off from seniors.
• Lead preparation and review of Local File, Master File and CbCR.
• Conduct CUP/TNMM/CPM/DEMPE analyses and benchmark studies.
• Manage TP disclosures in the annual CIT return and compliance calendar.
• Lead client responses to DGT TP audits and tax audits with timelines.
• Draft objection letters and appeals and coordinate with legal counsel.
• Represent the engagement team in meetings with tax auditors.
• Prepare unilateral and bilateral APA applications and supporting analysis.
• Manage MAP requests and coordinate with the Competent Authority process.
• Assist GMT/QDMTT impact assessments and GloBE computations.
• Support disclosures with clients' accounting teams (PSAK 46/IAS 12).
• Advise on TP planning, business restructuring and intercompany policy design.
• Manage engagement economics: scoping, budgeting, timelines and staffing.
• Coach, train and review Associates; contribute to proposals and training materials.

Descrição da oferta de emprego

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

TP Documentation & 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/Associates.
• Manage TP disclosures in the annual CIT return and related compliance calendar for a client portfolio.

TP Audit, Objection & Appeal

• Lead client responses to DGT TP 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 TP adjustments, coordinating with legal counsel where needed.
• Represent the engagement team in meetings with tax auditors and objection/appeal reviewers.

APA & 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 & Engagement Management

• Advise clients on TP 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/Senior Associates; contribute to proposals and technical training materials.