Verified Job
Accounting - Finance
Senior Manager - Transfer Pricing - CA
Accounting - Finance
#725854
Remote / WFH
Keiretsu Consultancy Services
Job Description
Job Description : Senior Manager Transfer Pricing
Department : Transfer Pricing
Level : Senior Manager
Qualification : Chartered Accountant (ICAI)
Post-Qualification Experience : 8 - 10 Years (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 :
Parameter : Requirement :
- 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 10A - 10THD 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
Department : Transfer Pricing
Level : Senior Manager
Qualification : Chartered Accountant (ICAI)
Post-Qualification Experience : 8 - 10 Years (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 :
Parameter : Requirement :
- 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 10A - 10THD 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
