Senior Associate/Senior Manager – Transfer Pricing – CA Serving Skill

The Corporate Institute; Delhi; On-site; INR 1,200,000 - 2,400,000; Full time

Job summary

The Corporate Institute in Delhi seeks a senior transfer pricing professional to lead documentation, benchmarking, and advisory work for Indian TP regulations. You will coordinate with clients, prepare Master/Local File submissions, and manage inter‑company analyses while guiding a team across multiple engagements.

Ideal candidates have strong TP regulatory exposure, experience in audits and APA engagements, and a track record of delivering high‑quality client-facing outputs.

Qualifications

• CA / MBA (Finance) or related qualification required
• 34 years of experience in Transfer Pricing
• Strong exposure to Indian Transfer Pricing regulations and compliance
• Experience in benchmarking studies and transfer pricing documentation

Responsibilities

• Prepare and review Transfer Pricing documentation including Local File, Master File, Form 3CEB, and contemporaneous documentation.
• Conduct benchmarking studies, FAR analysis, and economic analysis using relevant commercial databases.
• Work on inter-company transaction analysis and ensure compliance with Indian Transfer Pricing regulations and OECD Guidelines.
• Support BEPS-related compliance including Country-by-Country Reporting (CbCR), Master File, and Local File requirements.
• Assist clients in maintaining robust transfer pricing documentation and compliance frameworks.
• Handle transfer pricing assessments, audits, notices, and litigation proceedings before TPO, DRP, ITAT, and other authorities.
• Prepare submissions, technical responses, and supporting documentation for assessment proceedings.
• Support Advance Pricing Agreement (APA) engagements including unilateral, bilateral, and multilateral APA engagements.
• Coordinate with clients and senior counsel for litigation and dispute resolution matters.
• Lead and mentor Associates, Senior Associates, Assistant Managers, and junior team members.
• Review work products for technical accuracy and quality standards.

Skills

Transfer Pricing

Benchmarking studies

Client management

Leadership

Education

CA / MBA (Finance) or related qualification

CA (ICAI) – ACA/FCA

Job description

Key Responsibilities

Transfer Pricing Compliance & Documentation

• Prepare and review Transfer Pricing documentation including Local File, Master File, Form 3CEB, and contemporaneous documentation.
• Conduct benchmarking studies, FAR analysis, and economic analysis using relevant commercial databases.
• Work on inter-company transaction analysis and ensure compliance with Indian Transfer Pricing regulations and OECD Guidelines.
• Support BEPS-related compliance including Country-by-Country Reporting (CbCR), Master File, and Local File requirements.
• Assist clients in maintaining robust transfer pricing documentation and compliance frameworks.

Litigation, Assessments & APA Support

• Handle transfer pricing assessments, audits, notices, and litigation proceedings before TPO, DRP, ITAT, and other authorities.
• Prepare submissions, technical responses, and supporting documentation for assessment proceedings.
• Support Advance Pricing Agreement (APA) assignments including unilateral, bilateral, and multilateral APA engagements.
• Coordinate with clients and senior counsel for litigation and dispute resolution matters.

Advisory & Technical Research

• Conduct technical research on transfer pricing and international taxation matters.
• Advise clients on cross-border related party transactions, restructuring, operating models, and inter-company arrangements.
• Assist in drafting advisory notes, technical memorandums, and client presentations.
• Evaluate transfer pricing methodologies including CUP, RPM, CPM, TNMM, and Profit Split Method.
• Identify tax planning opportunities and proactively assess transfer pricing risks.

Client Management & Execution

• Coordinate with clients for financial data, business information, and documentation requirements.
• Ensure timely execution of assignments while maintaining high-quality deliverables.
• Participate in client discussions and engagement management activities.
• Build and maintain strong client relationships and act as a trusted advisor.

Team Management & Leadership

• Lead and mentor Associates, Senior Associates, Assistant Managers, and junior team members.
• Review work products for technical accuracy and quality standards.
• Allocate resources effectively across multiple concurrent engagements.
• Conduct technical training sessions and contribute to internal knowledge-sharing initiatives.

Eligibility Criteria

For Senior Associate

• CA / MBA (Finance) / relevant qualification in Finance, Economics, or related fields
• 34 years of experience in Transfer Pricing
• Strong exposure to Indian Transfer Pricing regulations and compliance
• Experience in benchmarking studies and transfer pricing documentation

For Senior Manager

• Chartered Accountant (ACA/FCA) from ICAI
• 810 years of post-qualification experience with at least 67 years in Transfer Pricing
• Experience in Big 4, reputed CA firms, or multinational transfer pricing teams preferred
• Hands-on exposure to litigation, TPO proceedings, DRP, ITAT, and APA assignments