Team Member - Transfer Pricing - Pharma

4. Key Accountabilities:

Accountability Cluster Major Activities / Tasks:

I. Develop Transfer pricing policy and prepare Transfer Pricing Compliance Master for Cipla group in order to establish the price setting for related party transactions - Formalise and establish Global Transfer Pricing policy for the Cipla Group in order to help businesses comply with the set regulations with respect to the same

- Implement the pricing policy by establishing and setting it in SAP in order to facilitate the related parties transactions

- Control the transfer prices set in SAP Price Master and specify and communicate the process to be implemented in SAP to the Business/Commercial Finance Team in order to ensure effective implementation

- Set and timely review the trigger points set in the SAP in order to identify and comply with the TP regulations

- Review and evaluate the tagging of related parties in SAP modules by setting a process to check correct capturing on transactions exceeding threshold limit under Companies Act/ SEBI Regulations in order to seek approval for covered RPT from Audit committee

- Review, formalise and analyse the agreements between related parties wherever needed and highlight the gaps (if any) in order to capture the same in the agreements from TP perspective

- Interact with teams and consultants from different geographies in order to update TP requirements in light of respective tax laws (majorly US, UK, Europe, SA, Uganda, Sri Lanka)

- Liaise with the consultants and provide relevant documents/details and calculations for cases of advance Pricing Agreement in order to submit the same to the APA authorities

II. Implement BEPS Action Plan 13 - TP Documentation (CbCR, Master File and Local File) and other BEPS Action Plans in order to meet the statutory timelines - Collate relevant information from various group entities and inter-company dealings in order to ensure timely preparation of the CbCR for Cipla Group to meet the statutory deadline

- Review Master File and local file and maintain the supporting documents prepared by external consultant in order to ensure timely statutory compliance

- Implement CbCR by assessing the documentation and analysing the results in order to highlight and address the key areas to be discussed with the management for corrective action

- Direct, monitor and guide the group entities on a continuous basis for the Action Plan 13 requirements by putting in place a master Checklist for the Cipla Group entities in relation to Action Plan 13 documentation

- Evaluate the tax implications and inter-company arrangements from BEPS Action plans (AP) such as AP 4, 6, 7, 8-10 and its recommendations and highlight the deviations in order to meet compliance

- Liaise with consultants on timely basis for meeting the deadlines and assist management in taking position on the issues from a technical stand point

III. Manage and complete Form 3CEB and other Transfer pricing Compliance requirements in order to meet the timelines for the financial year - Identify related party transactions ('RPT') from the financials and collate the support documents (e.g. relevant agreements/ analysis with related parties) to identify transactions covered under regulations

- Analyse and evaluate the information gathered and present the same to TP Auditor in order to meet arm's length analysis

- Specify the processes followed by the company to the external TP Auditor in order to comply and meet regulatory requirements and resolve ongoing queries during the TP Audit

- Collate and maintain the relevant information from various stakeholders and provide the same to TP Auditor on timely manner

- Review the Transfer pricing report and analysis provided by external consultant

IV. Prepare and review the transfer pricing analysis in order to ensure compliance with various statutory regulations (i.e. TP, SEBI Listing Agreement, Companies Act) - Understand and evaluate new RPT by discussing the business objectives with various stakeholders (Business Heads, group entities) and explain the transactions to consultants by arranging functional interviews in order to achieve timely transfer analysis and compliance objective

- Gather relevant details and resolve queries of external consultant by ensuring timely formation of TP Policy per transaction and analysing the consistency with other similar transactions and group's TP policy

- Conduct transfer pricing awareness, periodic workshops to implement best practices

- Analyse and review the benchmarking analysis prepared by external consultant for final sign offs

- Implement SAP based reports and controls for meeting compliance objective

5. Major Challenges:

- Dealing with multiple stakeholders across geographies, across business teams and consultants and ensuring consensus for achieving business objective and statutory compliance at same time

Overcome by : Being proactive in liaising between the stakeholders

- Continuous new developments in TP regulations on regular basis affects the compliance

Overcome by : Keep updating self with new developments in TP arena and regularly track the new regulations affecting Cipla

- Align the technical position agreed on consensus with auditors and business teams

Overcome by: Constant follow-up with the teams and regular feedback to agree and arrive on a consensus for setting price

- Meeting statutory guidelines , reporting timelines and operational discipline

Overcome by: meticulous planning to achieve statutory and reporting timelines

6. Key Interactions:

Internal External:

- Finance team (Accounts, Costing, FP&A)

- Company Secretarial team

- Business Heads and CFO of all group entities

- Tax / Finance Heads from various geographies - Transfer Pricing Officer (during TP Audit on annual basis)

- External consultants (Currently with EY, PwC, KPMG, Abhay Kale, KNAV)

- CIT (A) / DRP (on annual basis)

- External Counsel (on need basis)

7. Dimensions

Transaction values under TP ambit:

Cipla India: International transactions under TP: INR 1500 crore; domestic transactions: INR 600 crore

Over and above from Companies Act / SEBI perspective not covered above: INR 200-400 crore (estimate)

India and Overseas entities: INR 800-1000 crore (estimate)

TP Queries and new transaction analysis involved: 7-10 unique transactions (India entities) and 8-10 unique transactions (Overseas entities)

8. Key Decisions:

Decisions Recommendations:

- Submit relevant data to the external consultants after sufficient analysis Formalise the transfer pricing policy in consultation / post review of the Head-Tax

- Review of the TP report and highlighting the key observations to Head - Taxation/Tax Lead Formalise the TP Compliance Master and first time CbCR and other BEPS Action Plan

- Review the TP analysis prepared by the consultants Arranging for the workshops to business stakeholders on Transfer Pricing and key developments

Conduct functional interviews for certain transactions Finalising the terms of the agreements meeting transfer pricing perspective

Comments:

9. Skills & Knowledge

Educational qualifications:

BCom, Chartered Accountant (plus qualification of LLB/CS is added advantage to understand the tax laws and regulatory requirements)

Relevant experience:

- Minimum 5 years of relevant experience in Transfer Pricing from Big4 or similar role in transfer pricing at BSE30 company with global footprint

- Good analytical skills

- Understanding and interpretation of laws

- Conducted / Prepared the Transfer pricing reports and benchmarking analysis

Soft Skills :

- Excellent inter-personal and project management skills