Senior Manager – Transfer Pricing – CA Serving Skill

The Corporate Institute; Hinoba-an; On-site; PHP 900,000 - 1,700,000; Full time

Job summary

The Corporate Institute seeks an experienced Transfer Pricing specialist to lead client engagements and provide expert guidance on TP documentation, benchmarking, and compliance.

You will advise on intercompany transaction structuring, respond to tax authorities, and coordinate with clients and senior counsel for complex matters. Strong leadership and global BEPS knowledge are essential.

Qualifications

• Chartered Accountant (ACA/FCA) from ICAI or equivalent
• 8–10 years post-qualification experience, with 6–7 years in Transfer Pricing
• Big 4 / mid-size CA firm or in-house TP team experience preferred
• Broad sector exposure: IT/ITES, pharma, manufacturing preferred
• Hands-on experience with TPO, DRP, ITAT
• Desirable APA experience

Responsibilities

• Lead end-to-end delivery of transfer pricing engagements including documentation, benchmarking studies, and compliance filings.
• Prepare and review Transfer Pricing Study Reports (Form 3CEB and contemporaneous documentation) for Indian and multinational clients.
• Advise clients on structuring intercompany transactions in a tax-efficient and arm’s length manner.
• Manage transfer pricing assessments, respond to notices from TPO, and coordinate with clients during audits.

Skills

Transfer pricing knowledge

OECD BEPS guidelines

Intercompany structuring

Audit and dispute experience

Tools

Prowess

Capitaline

BvD/Orbis

ktMINE

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