Transfer Pricing

Note: Candidates has to be CA with 5+ years of experience in CA and 4 years experience in TP

Role Overview: We are looking for a dedicated Transfer Pricing professional to manage end-to-end deliverables for a German bank (India branches), a global HFT hedge fund's Indian entity, and multiple portfolio companies. You will be responsible for ensuring regulatory compliance, driving litigation strategy, and providing value-added advisory services.

Key Responsibilities:

• Compliance & Litigation:
• Manage comprehensive TP compliances, including Form 3CEB, TP documentation, and BEPS compliances (Country-by-Country report, Master File, and CbC notifications).
• Document the need-benefit test for high-value cost allocations by collaborating with the India Tax Head and divisional leaders to templatize requirements and define cross-functional roles for real-time data maintenance.
• Lead transfer pricing assessments for the High Frequency Trading (HFT) entity in India, including technical submissions and defense strategy.
• Successfully handle litigation matters, including overturning established precedents at the first level of litigation to secure significant tax relief.
• Advisory:
• Prepare planning memoranda to design pricing models for proposed entities (e.g., server entities in India).
• Conduct interviews with fund founders to establish management fee splits and cash-flow structuring between feeder, master funds, and support service entities.
• Lead benchmarking analyses, including guarantee fees, royalties, cost-plus mark-ups, and intercompany interest rates.
• Manage Unilateral Advance Pricing Agreements (APA) for royalty payments regarding proprietary technology/trading algorithms.
• Business Development & Coordination:
• Conduct budget TP updates for clients and participate in internal budget discussions.
• Assist in business development activities, including drafting proposals and preparing pitch packs for prospective clients.
• Liaise with international network offices and cross-functional teams to devise holistic tax solutions.

Education
Chartered Accountancy (C.A)
Skills Required
Transfer Pricing