Job Title:  Senior Manager | TP Advisory, Compliance, APA and Controversy management | Hyderabad | Transfer Pric

About the role

Based in Hyderabad, India, the Lead – Transfer Pricing reports to the Global Transfer Pricing Manager and plays a key role in driving global compliance and strategic alignment of our transfer pricing policies.

You’ll work closely with the Global Transfer Pricing Manager on high-impact initiatives including global audits, tax governance, and cross-border projects. The role involves partnering with regional business units, supply chain, corporate and local finance, and treasury teams to implement and maintain transfer pricing policies that support global operations.

What you will be doing

• Ensure compliance with global and local transfer pricing regulations, minimizing risk exposure.
• Lead the full transfer pricing cycle, including Country-by-Country Reporting (CbCR), Master File, and Local File requirements—covering data collection, functional interviews, benchmarking, and documentation.
• Manage and mentor a team of two Transfer Pricing Specialists.
• Oversee the preparation and review of transfer pricing documentation, ensuring alignment with OECD guidelines and local laws.
• Partner with Finance and Business teams to ensure transfer pricing outcomes are accurately reflected in financial results.
• Monitor and implement changes in transfer pricing legislation, including Pillar 2 developments, and assess their impact the Group
• Support audits, MAP proceedings, and APA processes, including responses to tax authorities.
• Collaborate with internal stakeholders across Finance, Tax, and Business Units to develop and execute effective transfer pricing strategies.
• Maintain consistency in intercompany pricing and agreements, recommending adjustments where needed.
• Coordinate with auditors for statutory, tax, and internal audit requirements.
• Provide training and guidance on transfer pricing principles to internal teams.
• Use our global SAP platform to manage transfer pricing data and processes.
• Assist in quarterly and ad hoc pricing calculations for intercompany transactions.
• Contribute to our overall tax strategy, ensuring alignment with business goals and sustainable practices.

What you will bring

• A professional qualification in Tax, Finance, Accounting, Economics, or a related field (CA/CPA preferred).
• At least 7 years of experience in transfer pricing, ideally within a Big 4 firm or a multinational organization.
• Strong understanding of OECD transfer pricing guidelines and global tax regulations.
• Proven track record in managing audits, compliance, and advisory projects related to transfer pricing.
• Excellent analytical and problem-solving skills, with the ability to manage stakeholders effectively.