Senior Associate/Senior Manager - Transfer Pricing - CA

Key Responsibilities:

Transfer Pricing Compliance & Documentation

• Prepare and review Transfer Pricing documentation including Local File, Master File, Form 3CEB, and contemporaneous documentation.

• Conduct benchmarking studies, FAR analysis, and economic analysis using relevant commercial databases.

• Work on inter-company transaction analysis and ensure compliance with Indian Transfer Pricing regulations and OECD Guidelines.

• Support BEPS-related compliance including Country-by-Country Reporting (CbCR), Master File, and Local File requirements.

• Assist clients in maintaining robust transfer pricing documentation and compliance frameworks.

Litigation, Assessments & APA Support:

• Handle transfer pricing assessments, audits, notices, and litigation proceedings before TPO, DRP, ITAT, and other authorities.

• Prepare submissions, technical responses, and supporting documentation for assessment proceedings.

• Support Advance Pricing Agreement (APA) assignments including unilateral, bilateral, and multilateral APA engagements.

• Coordinate with clients and senior counsel for litigation and dispute resolution matters.

Advisory & Technical Research:

• Conduct technical research on transfer pricing and international taxation matters.

• Advise clients on cross-border related party transactions, restructuring, operating models, and inter-company arrangements.

• Assist in drafting advisory notes, technical memorandums, and client presentations.

• Evaluate transfer pricing methodologies including CUP, RPM, CPM, TNMM, and Profit Split Method.

• Identify tax planning opportunities and proactively assess transfer pricing risks.

Client Management & Execution:

• Coordinate with clients for financial data, business information, and documentation requirements.

• Ensure timely execution of assignments while maintaining high-quality deliverables.

• Participate in client discussions and engagement management activities.

• Build and maintain strong client relationships and act as a trusted advisor.

Team Management & Leadership:

• Lead and mentor Associates, Senior Associates, Assistant Managers, and junior team members.

• Review work products for technical accuracy and quality standards.

• Allocate resources effectively across multiple concurrent engagements.

• Conduct technical training sessions and contribute to internal knowledge-sharing initiatives.

**Eligibility Criteria:
For Senior Associate:**

• CA / MBA (Finance) / relevant qualification in Finance, Economics, or related fields

• 34 years of experience in Transfer Pricing

• Strong exposure to Indian Transfer Pricing regulations and compliance

• Experience in benchmarking studies and transfer pricing documentation

For Senior Manager:

• Chartered Accountant (ACA/FCA) from ICAI

• 810 years of post-qualification experience with at least 67 years in Transfer Pricing

• Experience in Big 4, reputed CA firms, or multinational transfer pricing teams preferred

• Hands-on exposure to litigation, TPO proceedings, DRP, ITAT, and APA assignments