Intangibles and DEMPE Governance Director

The mandate

The committee needs a continuing independent challenge to whether returns attributed to intangibles follow the people, decisions, funding and risk control that actually create and protect value. Legal ownership and policy language may be clear while operational conduct changes. The adviser's task is to keep development, enhancement, maintenance, protection and exploitation evidence connected to transfer-pricing conclusions and governance choices.

For nine months, the Director will conduct a weekly evidence review, a monthly sponsor session and one scheduled committee meeting. The opening period tests the intangible inventory and factual certifications; the middle period examines selected arrangements and changes in conduct; the closing period assesses whether the governance process will identify new or altered DEMPE facts without continued external prompting.

The role is influence-only, with no line authority, pricing approval, contract power or right to direct personnel. The adviser may require questions to be answered through the sponsor, challenge factual consistency, recommend reanalysis and advise governance that a conclusion lacks support. Technical owners propose positions and authorised executives accept or remediate risk.

Relationships with advisers, counterparties, valuation providers or boards connected to relevant arrangements must be disclosed before access. The Director will recuse where prior privileged knowledge or economic interest compromises independent challenge. Renewal depends on a newly articulated governance question; it is not automatic because implementation activity continues.

What you will own

• Test the intangible inventory for completeness, legal ownership, economic significance, lifecycle stage and connection to controlled transactions.
• Challenge DEMPE factual profiles against named decision makers, budgets, employment records, approval evidence, risk-control conduct and actual outcomes.
• Press management to distinguish routine execution, strategic control, funding capacity and assumption of financially significant risk.
• Review whether pricing methods and returns remain coherent when functions, personnel, rights or exploitation models change over time.
• Shape a change-trigger protocol for acquisitions, restructurings, leadership movement, new development, abandonment and legal-right modification.
• Facilitate two red-team reviews in which factual owners defend selected profiles against contradictory operational evidence.
• Recommend a board dashboard separating legal title, functional conduct, pricing consequence, evidence strength and action ownership.
• Provide a final independent view on governance maturity, unsupported positions and the questions that should survive the advisory term.

Candidate qualifications

• At least 18 years in transfer pricing, with Director-level responsibility for intangibles, DEMPE analysis and senior governance communication.
• A case where observed decision conduct changed an intangible return or method despite apparently clear legal ownership.
• Deep knowledge of DEMPE functions, risk-control analysis, funding, options realistically available, valuation and hard-to-value-intangible considerations.
• Evidence of testing factual profiles through operational records and interviews rather than repeating policy or job-description assertions.
• Experience challenging senior leaders on where strategic control truly occurred while preserving accountable ownership of the conclusion.
• A conflict record compatible with sensitive intangible, valuation and counterparty information across concurrent appointments.
• Availability for three days a week and all scheduled Stockholm governance sessions during the term.

Working terms and boundaries

• The retainer covers three days a week for nine months, weekly evidence reviews and one board or committee meeting each month.
• The adviser has no line authority and cannot approve pricing, amend contracts, direct personnel, perform valuations or accept tax risk.
• Detailed benchmarking, contract drafting, return preparation and controversy representation remain outside scope unless separately commissioned.
• Conflicts are reviewed before access and when new arrangements enter the review population, with recusal documented through the sponsor.
• Closure consists of a governance opinion, change-trigger protocol and knowledge transfer; renewal requires a distinct board question.

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 11 October 2026. Mandate reference TAX-ADV-2026-STO-23.