Qualification: Chartered Accountant (CA) / MBA (Finance)
Experience : 1 - 2 Years
Timing : 10:00 AM - 7:00 PM
- Ensure timely and accurate filing of Form 3CEB for all International Transactions and Specified Domestic Transactions (SDT).
- Prepare Transfer Pricing Study Reports and Master File Documentation in compliance with applicable regulations.
- Conduct economic analysis and benchmarking studies using Indian databases to determine the Arm's Length Price (ALP) by applying the Most Appropriate Method (MAM).
- Evaluate applicability of Safe Harbour Rules, particularly for IT/ITeS and R&D transactions.
- Review and draft intercompany agreements, including royalties, intra-group services, and cost allocation arrangements, ensuring alignment with economic substance.
- Provide advisory on intercompany transactions, including loans, corporate guarantees, and interest pricing in line with Transfer Pricing regulations.
- Support business restructuring initiatives by providing Transfer Pricing inputs and recommendations.
- Represent the organization before the Transfer Pricing Officer (TPO) and prepare detailed submissions, including factual and technical rebuttals.
- Draft objections against assessment orders and represent before the Dispute Resolution Panel (DRP) under Section 144C.
- Assist in litigation matters before CIT(Appeals) and ITAT, including coordination with legal counsel and preparation for hearings.
Key Skills & Competencies:
- Strong knowledge of Transfer Pricing regulations and Indian tax laws.
- Experience in economic analysis and financial modeling.
- Proficiency in database research tools (such as Prowess, Capitoline, etc.).
- Excellent analytical, drafting, and communication skills.
- Ability to handle litigation and representation matters.
