Intercompany Financial Transactions Pricing Director

The mandate

This project will create and prove a transfer-pricing framework for material intercompany loans, guarantees, cash-pool positions and other financial transactions. The bounded problem is inconsistency among legal terms, treasury conduct, credit evidence, pricing method and booked results. The deliverable must support repeatable decisions and postings; it is not a commission to redesign treasury strategy or negotiate external financing.

The first milestone, due after six weeks, is a verified instrument inventory and fact record covering purpose, terms, conduct, currency, tenor, security, seniority, borrower capacity, options and actual cash flows. Milestone two, due at month four, is the approved method framework, data hierarchy, governance path and model specifications for each included transaction class.

Milestone three, at month seven, is a production-representative pilot containing pricing files, calculations, accounting instructions, exception decisions and sampled evidence. Final acceptance in month eight requires a controlled toolkit, training assessment, first-use review and residual-risk register signed by the International Tax Director and designated treasury-control owner.

The client will make agreements, treasury records, cash flows, financial forecasts, credit inputs, prior studies and owner interviews available against a dependency plan. Acceptance requires facts reconciled to conduct, transparent comparable or model choices, reproducible calculations and agreed posting controls. Treasury policy, legal renegotiation, tax filings, controversy representation and software purchase are excluded.

What you will own

• Reconcile the complete included instrument population to legal agreements, treasury records, cash movement, accounting balances and observed conduct.
• Establish borrower and lender factual profiles addressing debt capacity, alternatives realistically available, implicit support, security and decision authority.
• Define method-selection criteria for loans, guarantees and cash-pool outcomes, recording data hierarchy, adjustments and model limitations.
• Build calculation specifications covering rates, fees, currencies, reset dates, accruals, exceptions and accounting handoffs.
• Create a governance route for new instruments, modified terms, covenant stress, non-payment, guarantee calls and conduct inconsistent with contract.
• Run a pilot that reproduces selected prices and postings from controlled inputs, with defects logged and retested before acceptance.
• Assess designated operators through a new-instrument case and an existing-instrument exception rather than classroom attendance alone.
• Deliver the accepted framework, model files, factual templates, control evidence, exclusions and next-cycle ownership record.

Candidate qualifications

• At least 16 years in transfer pricing, tax economics or treasury taxation, including Director-level work on intercompany financial transactions.
• A completed framework covering more than one of loans, guarantees or cash pools, with proof that calculations and ledger outcomes operated after advice.
• Deep knowledge of credit analysis, debt capacity, implicit support, options realistically available, guarantee benefit, risk-free and risk-adjusted returns.
• Experience selecting and adjusting comparable data or valuation methods while making limitations visible to decision makers.
• Evidence of resolving divergence between written instrument terms and actual treasury conduct without treating legal form as conclusive.
• Ability to coordinate tax, treasury, legal and accounting owners while preserving their separate approval responsibilities.
• Fixed-deliverable discipline including explicit dependency management, model validation, operator testing and formal acceptance.

Working terms and boundaries

• The eight-month assignment requires four days a week and releases fees against four accepted milestones, not accumulated hours.
• Tax accepts pricing methodology; the treasury-control owner separately accepts instrument facts, operating governance and accounting handoffs.
• Complete agreements, treasury records, forecasts, credit inputs and owner access are scheduled client dependencies.
• External financing strategy, legal renegotiation, return filing, controversy defence and platform purchase remain outside the fee.
• Final acceptance requires a reproducible pilot, cleared critical model defects, tested operators and signed residual-risk ownership.

Application

Applications for this mandate are received in one way only: through the India Board Terminal's application process. It is automated end to end. Your Executive Passport travels to the mandate holder in its confidential form, your answers to the three questions below are read before anything else in your file, and every stage that follows is recorded on your applications page.

There is no address to write to and no intermediary to call. The mandate holder reads what the Terminal delivers and nothing else, which is what keeps the process the same for every applicant and keeps your name out of it until you release it. Applications close on 8 October 2026. Mandate reference TAX-CON-2026-CPH-20.