Job Description: Manager International Taxation & Transfer Pricing Location - Kolkata

Position Summary

The Manager – International Taxation & Transfer Pricing will be responsible for end-to-end execution of cross-border tax and TP engagements, including advisory, compliance, and litigation support. The role also requires practical experience in FEMA regulations and Company Law matters, enabling holistic structuring of inbound and outbound transactions.

Key Responsibilities

1. International Tax Advisory & Compliance

- Advise clients on:
- Cross-border transactions, structuring, and tax implications
- Withholding tax (Section 195), equalisation levy, PE exposure
- Tax treaty interpretation and DTAA analysis

- Handle tax opinions, memos, and advisory notes
- Support in tax assessments, DRP, and appellate proceedings

2. Transfer Pricing (TP)

- Prepare and review:
- TP documentation (Local File / Master File)
- Benchmarking studies using databases (Prowess, Capitaline, Bloomberg, Royalty Stat/Royalty Range etc.)

- Conduct FAR analysis and recommend appropriate TP methods
- Assist in:

- APA / MAP proceedings
- Litigation and audit defense

3. FEMA & Cross-Border Regulatory Compliance

- Handle FEMA matters including:
- FDI / ODI structuring and reporting (FC-GPR, FC-TRS, ODI filings)
- External Commercial Borrowings (ECB)
- Pricing guidelines and valuation compliance

- Liaise with banks, AD dealers, and regulatory authorities

4. Company Law (Corporate Compliance)

- Manage Company Law matters under the Companies Act, 2013:
- Incorporation of entities (including foreign subsidiaries/JVs)
- Board/shareholder resolutions for cross-border transactions
- ROC filings and secretarial compliance




- Corporate Governance in relation to Related Party transactions

- Coordinate with Company Secretaries and legal advisors

5. Client Handling & Execution

- Independently manage mid-size clients and engagements
- Act as single point of contact for execution and delivery
- Ensure timelines, quality, and client satisfaction

6. Team Management & Mentoring

- Supervise and review work of Associates / Senior Associates
- Provide technical guidance and on-the-job training
- Assist in team development and knowledge sharing

7. Business Development Support

- Assist Partners/Directors in:
- Proposal preparation and pitch decks
- Identifying cross-selling opportunities

- Contribute to thought leadership (articles, alerts)

Key Competencies

- Robust technical knowledge of:
- International Tax & Transfer Pricing provisions
- OECD TP Guidelines & BEPS developments
- FEMA regulations and RBI guidelines
- Companies Act, 2013/SEBI

- Analytical and problem-solving skills
- Effective communication and client management
- Ability to handle multiple engagements under tight timelines

Qualifications & Experience

- Chartered Accountant (CA) mandatory
- 5–6 years of relevant experience in a reputed Firm
- Hands-on experience in:
- TP documentation & benchmarking
- International Tax Matters
- FEMA filings and advisory
- Company law compliance

KPIs / Success Metrics

- Timely and accurate delivery of assignments
- Quality of documentation and advisory
- Client satisfaction and retention
- Team productivity and mentoring effectiveness
- Contribution to revenue and cross-selling

Reporting Structure

- Reports to: Director / Partner – International Tax & TP

Compensation – Commensurate as per Industry Standards

📌 Manager - International Taxation & Transfer Pricing (Kolkata)
🏢 Constantia Centre Of Excellence
📍 Kolkata