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 skilled 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.

📌 Transfer Pricing (Bengaluru)
🏢 Wroots Global Private
📍 Bengaluru