Senior / Assistant Manager - Transfer Pricing

Client advisory and delivery • Advise clients on tax and transfer pricing issues arising from value chain alignment, business model optimization, and operating model change. • Support projects involving business restructurings, principal structures, distribution model changes, service model design, regional hub arrangements, and supply chain realignment. • Analyze functions, assets, risks, and profit allocation across multinational groups to assess alignment with commercial substance and value creation. • Assist clients in identifying tax risks, transfer pricing issues, and implementation challenges arising from current or proposed structures. • Support the design of tax-efficient and commercially robust operating models, including consideration of cross-border tax, transfer pricing, and controversy implications. • Contribute to advice on substance alignment, DEMPE-related issues, intangible ownership and development structures, and regional operating models. • Prepare clear, well-structured deliverables including reports, technical memoranda, presentations, workshop materials, and executive summaries. Project management • Manage day-to-day delivery of client engagements, including planning, execution, team coordination, timelines, and quality control. • Work closely with other members of the Tax team across transfer pricing, international tax, indirect tax, and tax policy, and coordinate with other service lines where appropriate. • Supervise and review the work of junior team members, providing guidance, feedback, and on-the-job development. • Ensure that advice is technically robust, commercially relevant, and delivered in a practical and timely way. Business development and team growth • Support the development of the Tax team’s value chain alignment offering and related market propositions. • Assist with proposals, pitch materials, fee estimates, and internal business cases. • Identify opportunities to expand client relationships by connecting transfer pricing and tax issues to broader business changes and challenges. • Contribute to thought leadership, internal training, and client-facing materials on value chain alignment, tax policy developments, and business restructuring trends. Stakeholder engagement • Work closely with Tax Partners and Directors on strategic client engagements and practice development. • Build effective working relationships with client tax, finance, legal, and business stakeholders. • Collaborate across jurisdictions on regional and global projects involving multinational clients. Qualifications & Experience Preferred areas of experience We are looking for candidates with experience in several of the following areas: • Transfer pricing advisory and planning. • International tax advisory. • Business restructurings and operating model changes. • Value chain analysis and substance alignment. • DEMPE analysis and intangible-related issues. • Distribution, principal, service, and procurement models. • Tax controversy risk identification and audit readiness. • Tax aspects of supply chain change, regionalization, and business transformation. Qualifications and experience • Bachelor’s degree in Accounting, Law, Economics, Finance, Business, Tax, or a related discipline. • Min 2 years of relevant experience in transfer pricing, international tax, or related tax advisory work. • Strong experience in a professional services or multinational tax environment. • Good understanding of OECD transfer pricing principles and their practical application. • Experience managing projects and teams on cross-border advisory engagements. • Strong written and verbal communication skills. • Ability to explain complex tax and transfer pricing issues in a clear and practical way. • Experience working with multinational groups in APAC is preferred. Key skills and attributes • Strong technical tax and transfer pricing capability. • Commercial awareness and the ability to connect tax advice to business realities. • Strong analytical and problem-solving skills. • Good project management and organizational capability. • Ability to manage multiple workstreams and priorities. • Strong collaboration and stakeholder management skills. • A proactive and entrepreneurial mindset. • Commitment to high-quality client service and team development.