Job Title: Assistant Manager - Transfer Pricing Specialist (Shared Service Centre, India)

Department: Tax (Group Tax)

Reporting To: Senior Manager – Transfer Pricing

Location: Noida

Role Purpose The role holder will be based at the Shared Service Centre in India and will work as an extension of the Group Tax team in Dubai, collaborating day-to-day with the Senior Manager – Transfer Pricing. The role requires a professional who can draft, analyse, and deliver under Senior Manager supervision, supporting the group’s transfer pricing documentation, benchmarking, intercompany financing, and multi-jurisdiction compliance obligations across the DAMAC entity perimeter.

Key Responsibilities

TP Documentation – Local File and Master File

- Draft and review Local Files and Master Files across all relevant DAMAC entities, in line with UAE CT Law (Federal Decree-Law No. 47 of 2022), Ministerial Decision No. 97 of 2023, and OECD BEPS Action 13.
- Prepare the group’s intercompany transaction matrix, capturing all related-party flows (services, loans, royalties, recharges, guarantees) across the full entity perimeter.
- Conduct and document functional analyses, risk analyses, and economic characterisations for new and existing intercompany arrangements across UAE Mainland, Freezone, UK, India, and data centre entities.

Benchmarking Studies and Arm’s-Length Pricing

- Review benchmarking deliverables from external advisers, providing substantive technical commentary on methodology, comparator selection, and pricing conclusions before internal sign-off.
- Identify and apply the most appropriate TP methodology (CUP, TNMM, Profit Split, Cost-Plus, Resale Price) for each intercompany transaction category, with documented rationale consistent with OECD Guidelines and UAE TP Regulations.

Intercompany Financing Transactions

- Review intercompany loan IOMs and internal approval memoranda to ensure TP and CT risks are adequately identified and disclosed, not solely the tax advantages of the arrangement.
- Support preparation and review of novation agreements and related legal documentation to formalise intercompany arrangements in line with arm’s-length principles.




- Monitor intercompany balances and review GL dump outputs to ensure intercompany payables and receivables are correctly classified, described, and distinguishable from operational flows.

Advisory

- Maintain and update support documents for relevant entities and co-ordinating with advisers to ensure assessments remain current and defensible.
- Support the TP review of CT returns and other filing advisers for various jurisdictions where DAMAC has a taxable presence.
- Prepare related-party (RP) schedules for income tax return purposes as required by filing advisers.

Audit and Tax Authority Defence

- Draft TP defence memoranda and support the collation of data and preparation of schedules for tax authority audits and queries.

Related-Party Financial Statement Review

- Review draft financial statements of DAMAC group entities for TP purposes, covering completeness and accuracy of related-party disclosures and arm’s-length characterisation of disclosed transactions.
- Confirm intercompany service, loan, and recharge arrangements reflected in financial statements are consistent with documented TP policies, intercompany agreements, and arm’s-length pricing analyses.
- Identify and flag instances where descriptions or classifications of intercompany amounts in the GL or financial statements create TP or CT risk.

New Business and Structural Transactions

- Provide TP input on new intercompany arrangements arising from the Group’s ongoing expansion.
- Support the drafting and review of intercompany agreements (service agreements, loan agreements, investment advisory agreements) for consistency with arm’s-length principles and TP documentation positions.
- Prepare or review TP position papers and internal advisory memos on emerging or complex TP matters, with clearly structured analysis and documented conclusions.

External Adviser Management and Technical Research

- Act as the day-to-day liaison with external TP advisers,



reviewing deliverables critically and providing substantive written feedback before internal sign-off.
- Conduct targeted research on OECD Guidelines, BEPS Actions 8–10 and 13, UAE CT Law and TP Regulations, and local country TP rules, producing concise technical notes and position memos as required.
- Monitor international TP and CT developments relevant to DAMAC’s business (Pillar Two, FTA guidance updates, BEPS implementation in key jurisdictions) and brief the Senior Manager accordingly.

Internal Stakeholder Support

- Assist the Senior Manager in preparing internal briefing notes, position papers, and approval memoranda (IOMs) related to TP matters.

Required Experience & Qualifications

- 5–8 years’ experience in transfer pricing, preferably within a Big 4 / qualified services firm or a large multinational corporate.
- Strong practical experience in:
- Various TP regulations, including Local File and Master File preparation
- Benchmarking studies, functional analyses, and application of OECD TP methodologies
- Intercompany financing, intragroup agreements, and TP defence / audit support
- Bachelor’s degree in Accounting, Finance, Economics, Tax, or a related field.
- Professional qualification (ACCA, ACA, CTA, CPA, ADIT or equivalent) preferred.

Technical & Professional Skills

- Strong working knowledge of OECD TP Guidelines, and BEPS Actions 8–10 and 13;.
- Exposure to TP rules in multiple jurisdictions (e.g., UK, India, Qatar, Thailand, Indonesia, Spain, Italy, US).
- High level of proficiency in Excel and data analysis, including working with GL extracts and benchmarking databases.
- Excellent technical writing skills, able to draft clear TP memos, defence documents, and position papers with documented conclusions.
- Strong communication and stakeholder co-ordination skills, including managing external advisers.

Key Competencies

- Analytical, detail-oriented, and risk-aware
- Highly organised with strong time management across multiple jurisdictions and deadlines
- Comfortable working under pressure during filing and audit deadlines
- Strong sense of ownership and accountability
- Proactive problem solver, able to work independently and remotely under Senior Manager supervision

📌 Transfer Pricing Manager (Noida)
🏢 DAMAC Shared Services
📍 Noida