Job Description Manager Transfer Pricing / International Tax

Designation: Manager Transfer Pricing / International Tax

Department: Tax, Regulatory & Services (TRS)

Location: Bengaluru

Company: Desai Haribhakti & Co.

About Desai Haribhakti & Co.

Desai Haribhakti & Co. LLP is one of India's leading Chartered Accountancy firms, providing professional services in Audit & Assurance, Taxation, Advisory, Risk Consulting, Transaction Advisory, and Business Consulting. The firm serves a diversified client base, including multinational corporations, listed companies, private equity funds, family-owned businesses, and start-ups.

We are looking for a highly motivated Manager Transfer Pricing & International Tax with strong technical expertise, client management capabilities, and leadership skills to support the growth of our TRS practice.

Position Summary

The Manager will independently manage Transfer Pricing and International Tax assignments, including advisory, compliance, litigation support, and cross-border tax structuring. The role involves leading client engagements, mentoring teams, building client relationships, and supporting Partners in business development initiatives.

Qualification

Mandatory

- Chartered Accountant (CA)

Experience

- Minimum 710 years of post-qualification experience.
- Experience in reputed CA firms.
- Hands-on experience in Transfer Pricing and International Tax engagements.
- Experience in independently managing client portfolios.

Reporting To

- Partner – TRS
- Director / Associate Partner

Key Responsibilities

1. Transfer Pricing Advisory

- Advise multinational and domestic clients on Transfer Pricing regulations.
- Develop and implement Transfer Pricing policies.
- Review and prepare:
- Local File
- Master File
- Country-by-Country Reporting (CbCR)
- Accountant's Report (Form 3CEB)
- Conduct FAR (Functions, Assets & Risks) analysis.
- Undertake benchmarking studies using commercial databases.




- Assist clients in Transfer Pricing planning and policy implementation.
- Advise on inter-company pricing arrangements.

2. International Tax Advisory

- Advise clients on cross-border transactions.
- Provide tax-efficient structures for inbound and outbound investments.
- Advise on:
- DTAA
- Permanent Establishment (PE)
- Foreign Tax Credit
- Withholding Tax
- Equalisation Levy
- BEPS implications
- Review international contracts from a tax perspective.
- Support foreign investment structuring.
- Provide advisory on tax implications of global restructuring.

3. Transfer Pricing Compliance

- Prepare and review Transfer Pricing documentation.
- Ensure compliance with:
- Section 92 to 92F of the Income-tax Act
- OECD Guidelines
- BEPS Framework
- Review Form 3CEB.
- Ensure timely completion of annual Transfer Pricing compliances.

4. Transfer Pricing Litigation

- Handle Transfer Pricing audits.
- Draft submissions before:
- Transfer Pricing Officer (TPO)
- Assessing Officer (AO)
- Dispute Resolution Panel (DRP)
- Commissioner of Income Tax (Appeals)
- Income Tax Appellate Tribunal (ITAT)
- Coordinate with Senior Counsels and Advocates.
- Prepare appeal papers and litigation strategies.

5. International Tax Compliance

- Review withholding tax obligations.
- Review tax computations.
- Review foreign remittance documentation.
- Advise on FEMA compliance wherever applicable.
- Assist clients in obtaining lower withholding certificates.

6. Cross-border Transaction Advisory

Advise on:

- Foreign investments
- Overseas acquisitions
- Joint Ventures
- Business restructuring
- Cross-border financing
- Royalty arrangements




- Management service agreements
- Cost-sharing arrangements
- Inter-company financing
- Intellectual Property transactions

7. Client Relationship Management

- Manage end-to-end client engagements.
- Conduct technical discussions with CFOs, Finance Heads, and Tax Heads.
- Understand client business models.
- Deliver commercially viable tax solutions.
- Build long-term client relationships.
- Ensure timely project delivery.

8. Team Management

- Lead a team of Associates, Senior Associates, and Assistant Managers.
- Review deliverables before submission.
- Allocate assignments.
- Conduct technical training sessions.
- Mentor junior professionals.
- Perform periodic performance reviews.

9. Business Development

- Identify recent business opportunities.
- Participate in client pitches.
- Prepare technical proposals.
- Prepare fee quotations.
- Cross-sell other service lines.
- Build relationships with multinational companies and professional networks.
- Support Partners in revenue generation.

10. Research & Knowledge Management

- Track amendments in:
- Income-tax Act
- OECD Guidelines
- BEPS Developments
- CBDT Circulars
- Judicial Pronouncements
- Publish technical articles.
- Prepare client alerts.
- Conduct internal knowledge-sharing sessions.

Technical Expertise

The candidate should possess strong knowledge of:

- Transfer Pricing Regulations
- International Taxation
- Income-tax Act, 1961
- OECD Transfer Pricing Guidelines
- BEPS Framework
- DTAA
- Permanent Establishment (PE)
- Benchmarking Studies
- FAR Analysis
- Local File
- Master File
- CbCR
- Form 3CEB
- FEMA
- Foreign Exchange Regulations
- Equalisation Levy
- Cross-border Transactions
- Tax Structuring
- Withholding Tax
- Tax Treaties
- Global Tax Developments

Software Knowledge

Preferred experience in:

- Capitaline
- ProwessIQ
- Ace TP
- TP Catalyst
- Bloomberg
- Excel (Advanced)
- PowerPoint
- Word

📌 Chartered Accountant_Manager_Transfer Pricing / International Tax (Bengaluru)
🏢 Desai Haribhakti
📍 Bengaluru