Transfer Pricing Manager

HITACHI VANTARA INDIA PRIVATE LIMITED; Mumbai; On-site; INR 1,500,000 - 2,100,000; Full time

Job summary

Deloitte Tax Practice in Mumbai seeks a Transfer Pricing Manager to lead advisory engagements, develop client relationships, and deliver TP solutions across business restructurings, cost allocations, and APA processes.

You will coordinate with teams on documentation, litigation support, and policy recommendations, ensuring compliance and client satisfaction in high‑stake international transactions.

Qualifications

• CA or MBA Finance from a recognized institute.
• 5–7 years of Transfer Pricing experience.
• Experience drafting memos, notes, and presentations.

Responsibilities

• Provide transfer pricing advisory opinions across TP issues for clients.
• Advise on Business Model Optimisation and cost allocations.
• Review inter‑company pricing, APA processes, and compliance documentation.

Skills

Transfer Pricing

Client relationship

Memos and presentations

Education

CA or MBA Finance

Job description

The team

Innovation, transformation and leadership occur in many ways. At Deloitte, our ability to help solve clients’ most complex issues is distinct. We deliver strategy and implementation, from a business and technology view, to help you lead in the markets where you compete. Learn more about our Tax Practice

Your work profile

As a Manager in our Transfer Pricing team you’ll build and nurture positive working relationships with teams and clients with the intention to exceed client expectations. You will work on following aspects:

Advisory

Providing opinions in the form of memos, notes and presentations on various transfer pricing issuesAdvisory services on Business Model OptimisationAdvisory on application to Profit Split Method Advisory services on Specified Domestic TransactionsAdvisory services on cost allocations, cost contribution arrangements

Transfer Pricing advisory pertaining to business restructuring

Review of inter-company pricing arrangementsAdvising the client on possible transfer pricing exposures in relation to proposed international transactionsReview of costs allocation models

Advance Pricing Agreements (APA)

Assistance during all the stages of filing an APA applicationCoordination and liasoning with the client and APA authoritiesPreparation and review of APA applications

Compliance

Preparation of transfer pricing documentation for various multinational clientDetailed understanding of the business profile and functions, assets and risks of clientsResearch and analysis of the respective client industryIdentifying companies performing similar functions as of the clients using Indian and international databasePreparation of Form 3CEB

Audit proceedings

Handling transfer pricing assessments and appeals (at Transfer Pricing Officer,Dispute Resolution Panel, Commissioner of Income-Tax (Appeals) and Appellate Tribunal level)Compiling information required for preparation of submissions, and for providing clarifications that may be required by the Revenue authoritiesPreparing written submissions, as required, in connection with the revenue proceedings involving Analysis of various case lawsTime to time representations before the Revenue authoritiesAssisting the legal counsel in representing at the Tribunal LevelAssisted in drafting submissions and representing at the Tribunal Level

Others

Effective project and time managementPreparing presentations for various summits and conferencesGiven presentations in Firm's offsiteBalanced allocation of work to team membersGuiding and developing team membersDevelopment / promotion of the Deloitte Tax brand name – articles in publications, speaker at seminars, etc.Knowledge sharing with the team members including recent case laws, news articles, journals, etc.Training new joiners in the team

Key skills required:

CA or MBA Finance Primer Institutes5 – 7 years of Experience in Transfer Pricing