Manager - Global Transfer Pricing - Big4

We have positions for Manager - Global Transfer Pricing in Deloitte Shared Services India Pvt. Ltd for Bangalore.

CTC : Negotiable

Job Location : Bangalore

- Preference to CA 2007 or 2008 batch/LLB/MBA with 5 to 6 yrs experience

Reports to : Partner, Director and Senior Manager

Positions that reports to this position : Deputy managers, Assistant Manager, Tax Executives and Articled trainees

Primary purpose of the role : Providing tax advice and compliance support to various entities of the firm with respect to Transfer Pricing for Global/International

JD : Manager Global Transfer Pricing

Major responsibilities & deliverables :

Advisory :

- Providing opinions in the form of memos, notes and presentations on various transfer pricing issues

- Advisory services on Business Model Optimization

- Advisory on application to Profit Split Method

- Advisory services on Specified Domestic Transactions

- Advisory services on cost allocations, cost contribution arrangements

Transfer Pricing advisory pertaining to business restructuring :

- Review of inter-company pricing arrangements

- Advising the client on possible transfer pricing exposures in relation to proposed international transactions

- Review of costs allocation models

Advance Pricing Agreements (APA) :

- Assistance during all the stages of filing an APA application

- Coordination and liasoning with the client and APA authorities

- Preparation and review of APA applications

Compliance :

- Preparation of transfer pricing documentation for various multinational clients

- Detailed understanding of the business profile and functions, assets and risks of clients

- Research and analysis of the respective client industry

- Identifying companies performing similar functions as of the clients using Indian and international database

- Audit proceedings

- Handling transfer pricing assessments and appeals (at Transfer Pricing Officer, Dispute Resolution Panel, Commissioner of Income-Tax (Appeals) and Appellate Tribunal level)

- Compiling information required for preparation of submissions, and for providing clarifications that may be required by the Revenue authorities

- Preparing written submissions, as required, in connection with the revenue proceedings involving analysis of various case laws

- Time to time representations before the Revenue authorities

- Assisting the legal counsel in representing at the Tribunal Level

- Assisted in drafting submissions and representing at the Tribunal Level

Others :

- Effective project and time management

- Preparing presentations for various summits and conferences

- Given presentations in Firm's offsite

- Balanced allocation of work to team members

- Guiding and developing team members

- Development / promotion of the Deloitte Tax brand name - articles in publications, speaker at seminars, etc.

- Knowledge sharing with the team members including recent case laws, news articles, journals, etc.

- Training new joiners in the team.

Skills Required :

- Strong Technical knowledge

- Analytical skills & conceptual clarity

Qualifications required :

- CA or LLB or MBA Finance Primer Institutes.

Experience required, Any Specific Industry / Company exposure : 5 - 7 years Experience in Transfer Pricing.