Transfer Pricing & International Tax Manager

TaxPrime; Jakarta Utara; On-site; IDR 240,000,000 - 360,000,000; Full time

Benefits offered by this job

Outpatient medical reimbursement

Inpatient insurance

Hourly project incentives

Festival allowance

Job summary

TaxPrime is seeking a Transfer Pricing & International Tax Manager to lead day-to-day TP and international tax engagements, supervising a small team under Senior Manager/Partner guidance in Jakarta. You will own TP documentation, audits, APA/MAP processes, GMT/QDMTT impacts, and advisory work for client restructurings.

The role requires deep knowledge of TP documentation standards, TP audits, and cross-border tax planning, with strong Bahasa Indonesia and English communication skills.

Qualifications

• Bachelor's degree in Accounting, Economics, Finance, Law or related field; master's or Brevet C is an advantage.
• 5-7 years in transfer pricing/international tax with significant Big 4 or reputable advisory firm experience, plus 3 years in a managerial role.
• Knowledge of PMK 172/2023, PMK 213/2016, PMK 15/2025, PMK 136/2024 and OECD TP Guidelines.

Responsibilities

• Lead TP and international tax engagements, including fieldwork, deliverables, and supervising a small team.
• Prepare and review Local/Master File and CbCR, and conduct benchmarking studies.
• Manage TP disclosures in CIT return and tax calendar.
• Lead client responses to TP audits and objections, including preparing position papers and defense files.

Skills

Transfer pricing

International tax

Leadership

Client management

Financial analysis

Education

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

Master's degree or Brevet C advantage

Tools

Bloomberg/Orbis/Capital IQ

Job description

Transfer Pricing & International Tax Manager

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.

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.

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/international tax, with a significant portion in a Big 4 or reputable tax advisory firm, or the DGT's TP function, and have minimum 3 years experience in a managerial position.

Working knowledge of PMK 172/2023 (TP), PMK 213/2016 (TP documentation/CbCR), PMK 15/2025 (tax audit), PMK 136/2024 (GMT), and the OECD Transfer Pricing Guidelines.

Demonstrated experience across at least two of: TP documentation, TP audit defense, objection/appeal, APA, or MAP.

Strong economic/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/Senior Associate level).

Strong written and verbal communication in both Bahasa Indonesia (formal legal register) and English, including drafting objection/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 TP scrutiny (extractive industries, financial services, manufacturing) is an advantage.

Competitive salary package

Medical Reimbursement for out-patient

Third-party Insurance for in-patient

Hourly-based project incentive

Unlock job insights

Hirer responsiveness Salary match Number of applicants

Your application will include the following questions:

• How many years' experience do you have as an International Taxation Manager?
• How many years' experience do you have as a Transfer Pricing Manager?
• Which of the following languages are you fluent in?
• Which of the following types of qualifications do you have?
• What's your expected monthly basic salary?

Considered as one of Indonesian fastest growing tax firms, entailing significant growth since its initial establishment in 2012 and claiming its presence in Jakarta and Gresik, TaxPrime has the largest number of experts who formerly worked in the Indonesian Tax Authority, with strong expertise in risk identification and interpersonal skills as key factors in handling tax compliance, tax audits, and tax dispute resolution.

Its rapid development is supported by a number of young passionate professionals with expertise in Taxation, Customs, Business, and Management.

Considered as one of Indonesian fastest growing tax firms, entailing significant growth since its initial establishment in 2012 and claiming its presence in Jakarta and Gresik, TaxPrime has the largest number of experts who formerly worked in the Indonesian Tax Authority, with strong expertise in risk identification and interpersonal skills as key factors in handling tax compliance, tax audits, and tax dispute resolution.

Its rapid development is supported by a number of young passionate professionals with expertise in Taxation, Customs, Business, and Management.

Perks and benefits Medical Miscellaneous allowance Loans Parking Vision Income Tax Art. 21, Festival Allowance (THR)

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