Job : Transfer Pricing- Senior Analyst
Start date :
Immediate joiners only
About the role :
We are seeking a highly experienced and strategic
Transfer Pricing Analyst / Senior Manager
to lead and manage all aspects of the company’s transfer pricing function worldwide. This is a critical, high-impact role responsible for ensuring global compliance, mitigating tax risk, and contributing to the development of tax-efficient intercompany pricing strategies in alignment with our operational and financial objectives.
Key Responsibilities
1. Transfer Pricing Documentation & Compliance
Develop and maintain
comprehensive transfer pricing documentation, including
Master Files, Local Files, and Country-by-Country (CbC) Reports , in full compliance with local tax regulations and
OECD Transfer Pricing Guidelines .
Coordinate and manage the end-to-end documentation process, ensuring reports are accurate, complete, and prepared on a timely basis across all relevant jurisdictions.
Prepare and review transfer pricing
models and benchmarks
(e.g., comparable searches) to validate and support all intercompany pricing arrangements on an
arm's length basis .
2. Risk Management & Governance
Ensure rigorous compliance with evolving international and local transfer pricing laws to minimize tax risks and exposures globally.
Monitor and analyze
changes in global tax laws and regulations (e.g., BEPS initiatives) to proactively ensure transfer pricing policies remain current and compliant with international best practices.
3. Intercompany Agreements & Transaction Management
Lead the drafting, review, and execution of
intercompany agreements , ensuring all pricing terms, conditions, and legal documentation are fully consistent with the company’s transfer pricing policies.
Ensure all intercompany transactions (e.g., services, intangibles, financing) are properly documented, executed, and reflect commercial realities.
4. Strategic Advisory & Global Strategy
Serve as a key advisor to senior management on complex transfer pricing matters, providing strategic insights on efficient pricing structures, tax planning, and potential impacts on financial reporting.
Contribute significantly to the development and implementation of the company’s
global transfer pricing strategy , ensuring alignment with broader tax and business objectives across multiple jurisdictions.
Develop and implement strategies focused on tax exposure reduction and optimal management of intercompany pricing arrangements.
5. Collaboration, Audit & Dispute Resolution
Collaborate closely with internal
Finance, Tax, Legal, and Business Units
to assess, structure, and mitigate risks associated with intercompany pricing structures and operational changes.
Provide subject matter expertise, guidance, and training to internal stakeholders on transfer pricing principles and policy application.
Assist in the management and defense of
transfer pricing audits or disputes
raised by global tax authorities, working effectively with external advisors to achieve favorable resolutions.
Prepare timely and effective responses to inquiries from tax authorities.
Qualifications & Experience
Experience : Minimum of
5+ years
of progressive experience in transfer pricing, international tax, or finance, preferably gained within a multinational corporate environment or a "Big Four" public accounting firm.
Expert Knowledge :
Deep, practical experience with global transfer pricing documentation requirements (Master File, Local File, CbC).
Technical Proficiency :
Extensive familiarity with the
OECD Transfer Pricing Guidelines
and related global transfer pricing regulations, including a solid understanding of international tax treaties and local tax laws.
Skills :
Strong analytical, financial modeling, and research skills. Exceptional written and verbal communication skills required to articulate complex tax issues to non-tax audiences.
Education :
Bachelor’s degree in Accounting, Finance, Economics, or Law. A Master’s degree, CPA, or relevant professional certification (e.g., CFA) is highly desirable.
Pricing Analyst • Delhi, India