Mutual Agreement Double-Tax Relief Director

The mandate

This consulting engagement will create and execute a defined mutual-agreement case architecture for selected double-tax exposures. The problem is bounded to proving eligibility, building a consistent bilateral factual and economic record, preserving procedural rights and equipping accountable leaders to evaluate available resolution paths. It is not a general transfer-pricing documentation or litigation-support retainer.

Milestone one, due after six weeks, is a validated case inventory, eligibility opinion, deadline map and evidence-gap plan. Milestone two, due at month four, is the accepted submission architecture and reconciled factual-economic record. Milestone three, at month eight, consists of authority-ready responses and a controlled issue ledger reflecting substantive engagement.

Milestone four, due at month eleven, is a resolution model comparing credible bilateral outcomes, cash effects, accounting consequences and domestic alternatives. The final milestone is the complete case record, transfer plan and accepted residual-risk opinion at month twelve. Technical acceptance rests with the Head of Tax Controversy; procedural-file acceptance belongs to the authorised in-house legal owner.

The client will provide assessments, returns, prior submissions, agreements, economic studies, correspondence, accounting records and access to factual witnesses. Acceptance requires consistent facts across jurisdictions, protected deadlines, resolved critical evidence contradictions and decision-ready outcome ranges. Formal representation, new benchmarking, domestic litigation, accounting entries and settlement signature are excluded unless separately authorised.

What you will own

• Validate treaty eligibility, issue population, competent-authority deadlines, domestic-rights interaction and the completeness of claimed double taxation.
• Reconcile facts, tested transactions, economic analyses, filed positions, assessments and accounting records across both affected jurisdictions.
• Build an evidence hierarchy that distinguishes contemporaneous proof, management representation, inference and unresolved contradiction.
• Design authority submissions and response packs around the precise bilateral issue, avoiding unnecessary positions that expand controversy.
• Maintain a live issue ledger recording each authority's question, evidence supplied, remaining difference, deadline and accountable response owner.
• Model credible outcomes through tax, interest, cash timing, accounting, precedent and available domestic remedy rather than nominal adjustment alone.
• Prepare accountable leaders for authority meetings and resolution decisions without assuming representation or settlement authority.
• Deliver an accepted case archive, procedural calendar, decision model, open-issue record and post-engagement ownership plan.

Candidate qualifications

• At least 18 years in international tax controversy or transfer pricing, including Director-level responsibility for mutual agreement procedures.
• A completed bilateral case where you reconciled materially different factual or economic positions and achieved measurable double-tax relief.
• Deep knowledge of treaty MAP provisions, competent-authority practice, corresponding adjustments, procedural deadlines and domestic-right preservation.
• Evidence of identifying a contradiction between filed, assessed and economic records before it undermined bilateral credibility.
• Experience modelling resolution options through cash, accounting, interest, precedent and time—not headline tax adjustment only.
• Ability to prepare authority-ready materials while respecting in-house legal ownership and formal representation boundaries.
• Fixed-project discipline across long procedural timetables, including dependency notices, milestone evidence and accepted residual-risk transfer.

Working terms and boundaries

• The twelve-month engagement uses three days a week and five acceptance-linked milestones; elapsed authority time alone does not earn completion.
• Tax controversy accepts the technical case architecture, while in-house legal separately accepts procedural integrity and file completeness.
• Assessments, returns, prior papers, correspondence, economic analyses and factual-owner access are scheduled client inputs.
• Formal representation, new benchmarking, domestic litigation, accounting approval and settlement signature remain excluded absent written variation.
• Final acceptance requires protected rights, coherent bilateral facts, decision-ready outcome modelling and explicit ownership of unresolved authority actions.

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-BRU-28.