Business Restructuring Transfer Pricing Director

The mandate

This project will assess and document the transfer-pricing consequences of a defined business restructuring, from factual change through compensation and post-change operating control. The bounded problem is to identify what functions, assets, risks, rights or profit potential change, whether something of value is transferred or terminated, and how any compensation and future pricing should be determined.

Milestone one, due after six weeks, is a signed before-and-after factual baseline with decision conduct, contracts and realistic alternatives evidenced. Milestone two, at month three, is an options and delineation paper. Milestone three, at month six, is the accepted valuation or compensation analysis, including sensitivities and limitations.

Milestone four, due in month eight, is an implementation pack covering agreements, accounting instructions, future pricing, transition controls and change triggers. The final milestone is a witnessed first-use review, documentation dossier and residual-risk transfer at month nine. Technical acceptance belongs to the Global Transfer Pricing Head; implementation-control acceptance belongs to the designated controllership owner.

The client will provide approved restructuring decisions, current and proposed operating designs, agreements, forecasts, financial records, personnel evidence and factual-owner access. Acceptance requires coherent delineation, tested alternatives, defensible valuation inputs, reconciled entries and evidence that post-change conduct follows the design. Legal drafting, organisational execution, filing and controversy representation are excluded.

What you will own

• Establish before-and-after profiles of functions, assets, risk control, personnel, rights, contracts, decision location and expected profit potential.
• Identify transfers, terminations or renegotiations whose economic value requires analysis rather than assuming legal-entity movement alone creates compensation.
• Test the realistic alternatives available to affected parties and how those alternatives influence consent, pricing and indemnification.
• Evaluate valuation methods, forecasts, discounting, useful life, risk and sensitivity with explicit separation of fact and assumption.
• Define future controlled transactions and pricing methods consistent with the approved post-change conduct and allocation of risk.
• Specify legal, tax and accounting implementation steps, evidence owners, stop conditions and reconciliation requirements.
• Observe first use of the future-state pricing and trace selected entries to the approved policy and operating facts.
• Deliver accepted technical papers, model evidence, implementation controls, documentation and residual-risk ownership.

Candidate qualifications

• At least 17 years in transfer pricing, including Director-level leadership of a business restructuring and compensation analysis.
• A restructuring where factual testing showed that the proposed compensation was either unnecessary, incomplete or based on the wrong transferred value.
• Deep command of transaction delineation, realistic alternatives, profit potential, indemnification, valuation and post-restructuring pricing.
• Evidence of distinguishing legal changes from economically significant changes in functions, assets, risk control and rights.
• Experience challenging management forecasts or valuation assumptions without assuming authority over the business case.
• Ability to translate technical conclusions into agreements, entries, pricing controls and observable post-change conduct.
• Fixed-project delivery through separate technical and implementation acceptors, pilot evidence and controlled residual transfer.

Working terms and boundaries

• The nine-month project requires four days a week and is compensated through five artifact-based acceptance milestones.
• Transfer Pricing accepts delineation and valuation; controllership separately accepts accounting, future pricing and implementation-control evidence.
• Approved operating designs, agreements, forecasts, records and factual-owner access are dated client dependencies.
• Legal drafting, workforce or operational execution, filing and dispute representation are outside scope and require formal variation.
• Final acceptance requires reconciled implementation, witnessed first use, supported sensitivities and named ownership of remaining risks.

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-AMS-40.