Intangible Migration Tax Governance Director

The mandate

The committee needs an independent view on whether a proposed change in intangible ownership, rights or exploitation is supported by real decision conduct and a defensible economic comparison. The standing question goes beyond valuation: directors must understand what changes, what remains, which parties have realistic alternatives, and whether post-change people and risk control can sustain the intended tax outcome.

The six-month cadence includes a weekly evidence session, monthly sponsor review and one scheduled committee meeting. Early work will challenge before-and-after facts and alternatives; later sessions will examine valuation assumptions, implementation dependencies and post-change controls; the final review will assess whether governance can monitor conduct after the decision.

The adviser has no line authority, valuation sign-off, transaction vote, contract power or implementation mandate. The Director may question evidence, compare scenarios, recommend independent analysis and advise that a paper is not decision-ready. Management owns the proposal and authorised governance retains all approval and risk acceptance.

Relationships with valuation providers, advisers, counterparties, investors or boards relevant to the proposed change require disclosure. Recusal is mandatory where prior knowledge or economic interest cannot be safeguarded. Renewal needs a fresh governance question and will not convert the adviser into execution oversight.

What you will own

• Test before-and-after rights, functions, assets, risk control, decision location, personnel, contracts and expected exploitation.
• Challenge whether an economically significant transfer, termination or change occurs and which realistic alternatives affected parties possess.
• Review valuation methods, forecasts, discount rates, useful life, risk and sensitivity for coherence with factual conduct.
• Press management to distinguish legal ownership, funding, strategic control and routine execution in its proposed return allocation.
• Shape a decision comparison covering tax, cash, accounting, legal, implementation, controversy and unwind consequences.
• Review post-change agreements, pricing controls, personnel plans and conduct-monitoring triggers before final approval.
• Facilitate two board scenarios involving delayed personnel movement, changed forecast or control remaining with the original location.
• Provide a closing opinion on decision readiness, residual factual weakness and governance needed after implementation.

Candidate qualifications

• At least 20 years in international tax or transfer pricing, including Director-level advice on intangible transfers or migrations.
• A proposed intangible transfer you challenged or changed after testing conduct, alternatives or valuation assumptions.
• Deep command of DEMPE, risk control, options realistically available, hard-to-value intangibles, valuation and exit taxation.
• Evidence of linking legal and economic analysis to post-change people, decision and pricing controls.
• Experience advising boards without assuming valuation, transaction or implementation authority.
• A conflict record suitable for sensitive adviser, valuation and counterparty information.
• Availability for three days a week and all six Zurich committee reviews.

Working terms and boundaries

• The retainer covers three days a week, weekly evidence sessions and one board or committee review in each month.
• The adviser has no line authority and cannot value assets, approve transactions, amend contracts, direct staff or accept risk.
• Valuation production, legal drafting, implementation and filing are outside scope unless separately commissioned.
• Conflicts are refreshed as providers and counterparties enter the process, with recusal recorded by the sponsor.
• The appointment ends with a decision-readiness opinion and transfer session; renewal requires a distinct 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-ZRH-55.