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.