Senior Manager – Transfer Pricing – CA Keiretsu Consultancy Services

The Corporate Institute; New Delhi; On-site; INR 2,500,000 - 4,500,000; Full time

Benefits offered by this job

Flexible work arrangements

National/international training

Career progression to Director/Partner

Job summary

The Corporate Institute in New Delhi is seeking a Senior Manager to lead Transfer Pricing engagements across sectors, delivering advisory, compliance, and litigation support while mentoring juniors.

You will manage client relationships, handle TP documentation, BEPS issues, and cross-border structuring, with responsibility for end-to-end delivery and practice development.

Qualifications

• Qualified CA (ICAI) with 8–10 years post-qualification experience.
• At least 6–7 years in Transfer Pricing.
• Experience in Big 4 / mid-size CA firm or in-house TP team preferred.

Responsibilities

• Lead end-to-end delivery of TP engagements including documentation, benchmarking studies, and compliance filings.
• Prepare and review TP Study Reports (Form 3CEB and contemporaneous documentation).
• Advise on structuring intercompany transactions for tax efficiency and arm's-length compliance.
• Manage TP assessments, respond to notices, and coordinate with clients during audits.
• Represent clients before tax authorities and assist in APA negotiations and DRP/ITAT matters.

Skills

Transfer Pricing

TP documentation

Benchmarking

OECD/BEPS knowledge

Leadership

Client management

English communication

Education

Chartered Accountant (CA/ACA) from ICAI

Tools

Prowess

Capitaline

BvD/Orbis

ktMINE

RoyaltyStat

Job description

Job Description: Senior Manager Transfer Pricing

Department: Transfer Pricing

Level: Senior Manager

Qualification: Chartered Accountant (ICAI)

Post-Qualification Experience: 8-10 Years (Relevant 6 to 7 Years in Transfer Pricing)

Location: Hemkunt Colony, Opposite Nehru Place, New Delhi

About the Role:

We are looking for a dynamic and technically sound Senior Manager to join our Transfer Pricing practice in New Delhi. The incumbent will play a lead role in managing and delivering client engagements across industries, providing advisory, compliance, and litigation support services. This is a client-facing leadership role that also involves mentoring junior team members and contributing to practice development.

Key Responsibilities:

Client Delivery & Engagement Management:

• – Lead end-to-end delivery of transfer pricing engagements including documentation, benchmarking studies, and compliance filings under the Indian Income Tax Act, 1961 and relevant OECD/UN guidelines.
• – Prepare and review Transfer Pricing Study Reports (Form 3CEB and contemporaneous documentation) for Indian and multinational clients.
• – Advise clients on structuring intercompany transactions (services, goods, IP, loans, guarantees, cost-sharing arrangements) in a tax-efficient and arms length compliant manner.
• – Manage transfer pricing assessments, respond to notices from the Assessing Officer / Transfer Pricing Officer (TPO), and coordinate with clients during audit proceedings.
• – Represent clients before the TPO, Dispute Resolution Panel (DRP), Income Tax Appellate Tribunal (ITAT), and assist in High Court/Supreme Court matters in coordination with senior counsel.
• – Assist clients in Advance Pricing Agreement (APA) negotiations unilateral, bilateral, and multilateral and support rollback proceedings.
• – Advise on BEPS-related issues including Country-by-Country Reporting (CbCR), Master File, and Local File compliance.
• – Manage Safe Harbour Rule analysis and applications for eligible taxpayers.
• – Provide value chain analysis and global operating model advisory for restructuring engagements.

Technical & Advisory:

• – Conduct economic and functional analysis (FAR) for complex intercompany arrangements.
• – Carry out database searches and benchmarking using Prowess, Capitaline, Bureau van Dijk (BvD), and other commercial databases.
• – Advise on cross-border related party transactions across sectors including IT/ITES, pharmaceuticals, manufacturing, financial services, and e-commerce.
• – Stay abreast of developments in Indian and international transfer pricing jurisprudence, CBDT circulars, notifications, and OECD/G20 BEPS updates.
• – Identify planning opportunities and risk areas for clients proactively.

Team Leadership & Development:

• – Lead and mentor a team of Associates, Senior Associates, and Assistant Managers.
• – Review work products for technical accuracy, completeness, and client-ready quality.
• – Allocate and manage team resources across concurrent engagements.
• – Conduct periodic performance reviews and provide constructive developmental feedback.
• – Facilitate internal knowledge-sharing sessions and technical training for the team.

Business Development & Client Relationships:

• – Develop and maintain strong relationships with existing clients, acting as a trusted advisor.
• – Identify cross-selling opportunities across the firms service lines (direct tax, indirect tax, M&A, regulatory).
• – Contribute to preparing proposals, presentations, and thought leadership content.
• – Assist Partners in pitching for new client mandates.

Eligibility Criteria:

• – Qualification: Chartered Accountant (ACA/FCA) from ICAI
• – Post-Qualification Experience: 8-10 years, with at least 6-7 years in Transfer Pricing
• – Experience Setting: Big 4 / mid-size CA firm / in-house MNC TP team (CA firm experience preferred)
• – Industry Exposure: Broad sector exposure; IT/ITES, pharma, or manufacturing preferred
• – Litigation Experience: Hands-on experience with TPO proceedings, DRP, and ITAT
• – APA Experience: Desirable

Skills & Competencies:

Technical Skills:

• – Deep knowledge of Indian transfer pricing regulations (Sections 9292F of the Income Tax Act, 1961 and Rules 10A10THD of the Income Tax Rules, 1962)
• – Proficiency in OECD Transfer Pricing Guidelines and BEPS Action Plans (particularly Actions 810, 13, 15)
• – Strong command over benchmarking methodologies (CUP, RPM, CPM, TNMM, Profit Split)
• – Working knowledge of commercial databases (Prowess, Capitaline, BvD/Orbis, RoyaltyStat, ktMINE)
• – Familiarity with global tax treaty networks and their interaction with transfer pricing

Soft Skills:

• – Strong analytical thinking and commercial acumen
• – Excellent written and oral communication skills in English
• – Client management and stakeholder engagement ability
• – Ability to manage multiple engagements and meet deadlines under pressure
• – Leadership presence and collaborative working style
• – Attention to detail with a solution-oriented mindset

What We Offer:

• – Competitive compensation benchmarked to Big 4 / leading CA firm scales
• – Exposure to complex, multi-jurisdictional engagements
• – Clear and merit-based career progression to Director / Partner track
• – Access to national and international training programmes
• – Collaborative and intellectually stimulating work environment
• – Flexible work arrangements

Reporting Structure:

• – Reports to: Director / Partner Transfer Pricing
• – Manages: Managers, Assistant Managers, Senior Associates, Associates