Confidential mandate

Cost Contribution Arrangement Design Director

Planned Hiring / New

Cost Contribution Arrangement Design Director mandate in Copenhagen, Denmark

Confidential Cost Contribution Arrangement Design Director in Copenhagen, Denmark, reporting to the Global Transfer Pricing Head. Consulting Taxation appointment at Director level, a 10-month mandate horizon; four days a week.

The mandate

This project will design and validate a cost contribution arrangement for a defined pool of jointly developed or acquired benefits. The bounded problem is to determine eligible participants, expected benefits, contributions, control of risk, entry or exit consequences and balancing mechanics. The commission must prove operational feasibility; it is not a general intangible-policy or research-governance redesign.

Milestone one, due at month two, is an accepted participant and activity fact record. Milestone two, at month four, is the expected-benefit and contribution methodology with alternatives considered. Milestone three, at month six, is the valuation analysis for pre-existing contributions, buy-ins, buy-outs or adjustments relevant to the selected design.

Milestone four, due at month nine, is a controlled pilot containing source data, calculations, approvals, accounting entries and participant evidence. The final milestone is the accepted arrangement pack, operating handbook, training assessment and residual-risk record. Transfer Pricing accepts technical design; the named controllership owner accepts calculation and posting controls.

The client provides approved activity scope, participant facts, forecasts, budgets, existing rights, valuation inputs, accounting data and owner access. Acceptance requires credible expected-benefit measures, contribution alignment, documented risk control, reproducible balances and supported entry or exit rules. Contract drafting, operational reorganisation, filing and controversy defence are excluded.

What you will own

  • Establish participant profiles covering expected benefit, contribution capability, decision rights, risk control and realistic alternatives.
  • Define eligible development, acquisition or service activities and separate them from shareholder, duplicative or unrelated expenditure.
  • Design expected-benefit measures that are economically reasoned, measurable and capable of periodic reassessment.
  • Specify contribution valuation, balancing, true-up, entry, withdrawal and termination treatment with supporting assumptions.
  • Build calculation and accounting controls linking budgets, actual costs, allocation measures, approvals and participant balances.
  • Pilot the arrangement through production-representative data and a changed-benefit or participant scenario.
  • Assess permanent operators through an exception decision and independent reproduction of selected calculations.
  • Deliver accepted technical papers, valuation evidence, pilot files, controls, limitations and ongoing ownership.

Candidate qualifications

  • At least 17 years in transfer pricing, including Director-level design or review of cost contribution arrangements.
  • An arrangement where expected-benefit evidence changed participant scope, contribution share or continued eligibility.
  • Deep command of participation, expected benefits, risk control, contributions, buy-ins, buy-outs, balancing and valuation.
  • Evidence of rejecting an allocation measure that was administratively convenient but economically unrelated to expected benefit.
  • Experience translating technical design into budgets, actual-cost calculations, entries and recurring participant controls.
  • Ability to distinguish a cost contribution arrangement from intercompany services or a conventional licence.
  • Fixed-project completion using valuation evidence, live pilot, operator testing and separate acceptors.

Working terms and boundaries

  • The ten-month engagement requires four days a week and pays through five accepted milestones.
  • Transfer Pricing accepts participant and economic design; controllership separately accepts calculations and posting controls.
  • Activity scope, participant facts, forecasts, rights, valuation inputs and accounting records are scheduled client dependencies.
  • Legal drafting, operational redesign, filings and controversy support are excluded and require formal variation.
  • Final acceptance requires an operated pilot, tested participant change, reproducible calculations and signed residual 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 12 October 2026. Mandate reference TAX-CON-2026-CPH-60.

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