Advance Pricing and Mutual Agreement Strategy Director

The mandate

The board is repeatedly asked to choose whether material transfer-pricing uncertainty should be managed through an advance pricing agreement, mutual agreement procedure, domestic contest or continued documentation defence. The missing element is an independent comparison of time, evidence, bilateral dynamics, cash exposure, precedent and management capacity. The adviser will test route choices without taking conduct of any proceeding.

The twelve-month rhythm comprises a weekly case clinic, monthly sponsor review and quarterly committee attendance. Early work will establish route-comparison criteria and test the current portfolio. Later sessions will examine progress, changes in authority behaviour, evidence gaps and decision points where a case should continue, narrow, settle or move to another available mechanism.

The Director holds no line authority and cannot instruct counsel, negotiate with tax authorities, submit applications, approve settlement or make accounting conclusions. Influence is exercised through written challenge, scenario analysis and recommendations to the accountable sponsor. Case owners remain responsible for facts, submissions and procedural rights.

Prior or current relationships with involved authorities, advisers, counterparties or governing bodies require full disclosure. The adviser must recuse from any matter where confidential knowledge or perceived allegiance cannot be safely managed. The term ends with a portfolio-governance opinion; renewal requires the board to identify a distinct continuing question.

What you will own

• Develop a route-comparison framework covering technical strength, factual readiness, jurisdictional eligibility, expected duration, double-tax cash, precedent and resource demand.
• Challenge whether proposed bilateral or unilateral processes have a stable factual profile and operating model capable of surviving multi-year review.
• Test the consistency of advance-pricing positions with documentation, filed outcomes, accounting results and current operational conduct.
• Press case owners to identify procedural deadlines, information asymmetry, authority dependencies and the point at which a chosen route loses value.
• Review the governance of settlement ranges and double-tax exposure without recommending a number unsupported by accountable technical owners.
• Facilitate two committee simulations comparing continuation, narrowing, settlement and alternative-dispute paths under changing facts.
• Recommend portfolio measures that distinguish procedural movement, substantive risk reduction, cash recovery and unresolved precedent.
• Issue an independent closing assessment of route quality, governance discipline and decisions requiring board attention beyond the advisory term.

Candidate qualifications

• At least 20 years in transfer-pricing controversy, APAs or mutual agreement procedures, including senior responsibility for bilateral cases.
• A matter where you recommended against an APA or MAP despite technical eligibility, with the strategic reasoning and final accountable decision.
• Direct understanding of competent-authority process, bilateral negotiation dynamics, factual consistency, rollback implications and double-tax relief.
• Evidence of distinguishing procedural progress from genuine reduction in technical, cash or precedent exposure.
• Board-level advisory practice that remained separate from case execution, negotiation and formal representation.
• A conflict profile compatible with access to sensitive authority strategy across concurrent appointments and prior representations.
• Availability for two days a week and the full Hong Kong quarterly governance calendar.

Working terms and boundaries

• The retainer covers two days a week for twelve months, weekly case clinics, monthly sponsor reviews and four scheduled committee meetings.
• The adviser has no line authority and will not represent the organisation, instruct advisers, approve submissions, settle cases or sign accounting positions.
• Detailed case drafting, economic studies and additional authority-meeting attendance sit outside scope unless separately authorised.
• Conflicts are assessed at portfolio entry and again before each case review, with recusal recorded by the committee sponsor.
• Closure comprises the route-comparison framework, portfolio opinion and transfer session; any renewal must address a newly approved standing 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 7 October 2026. Mandate reference TAX-ADV-2026-HKG-19.