Senior Manager – Transfer Pricing – CA Serving Skill

The Corporate Institute; Delhi, Gurugram District, Dadri; On-site; INR 400,000 - 700,000; Full time

Job summary

The Corporate Institute in Delhi is seeking an experienced Transfer Pricing leader to drive client engagements, supervise reporting, and advise on intercompany structuring within a broad sector base including IT/ITES, pharma, and manufacturing.

You will guide teams through TP documentation, benchmarking, and BEPS compliance while coordinating with senior counsel on disputes and APA negotiations. A strong tax strategy mindset is essential.

Qualifications

• Chartered Accountant with ICAI designation (ACA/FCA).
• 8–10 years total post-qualification experience, with 6–7 years in Transfer Pricing.
• Experience in Big 4 / mid-size CA firm or in-house TP team preferred.
• Broad industry exposure IT/ITES, pharma, or manufacturing preferred.
• Hands-on TPO, DRP, and ITAT experience; APA exposure desirable.

Responsibilities

• Lead end-to-end delivery of transfer pricing engagements including documentation, benchmarking studies, and compliance filings under Indian rules.
• Prepare and review TP Study Reports (Form 3CEB and contemporaneous documentation) for clients.
• Advise on structuring intercompany transactions in a tax-efficient, arm’s length manner.
• Manage TP assessments, respond to notices, and coordinate with clients during audits.
• Represent clients before TPO/DRP/ITAT and support high court/supreme court matters with senior counsel.
• Support APA negotiations (unilateral/bilateral/multilateral) and rollback proceedings.
• Advise on BEPS issues including CbCR, Master/Local File compliance; Safe Harbour analysis.
• Lead and mentor Associates and Senior Associates; review work and allocate resources.
• Develop client relationships and identify cross-selling opportunities across service lines.

Skills

Team leadership

Client relationships

Business development

Transfer pricing knowledge

Education

Chartered Accountant (ACA/FCA) from ICAI

Tools

Prowess

Capitaline

BvD/Orbis

ktMINE

RoyaltyStat

Job description

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 arm’s 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 firm’s 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 92 – 92F of the Income Tax Act, 1961 and Rules 10A – 10THD of the Income Tax Rules, 1962)
• Proficiency in OECD Transfer Pricing Guidelines and BEPS Action Plans (particularly Actions 8 – 10, 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