Transfer Pricing Controversy Readiness Director

The mandate

The Director will create a permanent bridge between transfer-pricing policy, documentation and defence readiness before authority questions arrive. The role owns the quality of the factual and economic record for material exposures, the consistency of positions across jurisdictions and the speed with which accountable teams can produce truthful, reconciled evidence under challenge.

The first quarter will identify priority transaction families and test whether policies, agreements, functional conduct, calculations, local files, returns and accounting results tell the same story. Readiness will be measured through evidence retrieval, factual-owner confidence and issue-specific defence logic—not the existence of completed documents alone.

Authority includes setting readiness standards, selecting matters for red-team review, returning weak files, commissioning targeted economic or legal input and recommending controversy routes within delegation. Formal representation, settlement, litigation and reserved policy changes stay with authorised owners. The Director must ensure that preparatory work does not become undisclosed advocacy or create inconsistent positions.

By month twelve, priority matters must have current fact records, reconciled economics, contradiction logs, authority-response playbooks and named decision owners. Regional tax leaders should be able to run a mock examination, identify where evidence changes the position and escalate candidly without waiting for central authors to reconstruct the case.

What you will own

• Establish a controversy-readiness risk map using transaction value, factual change, outcome volatility, documentation weakness and authority focus.
• Reconcile priority positions across policy, agreements, conduct, calculations, documentation, filings and financial records.
• Create evidence indexes that identify source, custodian, period, privilege status, contradiction and permitted use under authority request.
• Conduct red-team examinations that test delineation, method choice, comparable evidence, losses, adjustments and implementation consistency.
• Require factual owners to resolve or explicitly acknowledge contradictions before response materials are approved for governance.
• Define escalation paths for weak positions, unavailable evidence, inconsistent jurisdictional claims and changes that may require policy reconsideration.
• Govern external economists and counsel through precise questions, complete facts, quality review and reusable decision outputs.
• Develop regional leaders through observed mock audits, response drafting and case-strategy forums with documented feedback.

Candidate qualifications

• At least 18 years in transfer pricing, including Director-level responsibility for audits, appeals, readiness or dispute-prevention portfolios.
• A case where readiness testing exposed a contradiction before an authority request, including the position or documentation change made.
• Deep command of transaction delineation, methods, comparability, financial analysis, local documentation and controversy process.
• Evidence of reconstructing a factual record without turning later recollection into falsely contemporaneous support.
• Experience coordinating policy, compliance and controversy owners while preventing inconsistent assertions across jurisdictions.
• A red-team methodology that tests both technical reasoning and the speed, provenance and credibility of evidence retrieval.
• Demonstrated development of regional tax leaders able to defend facts and recognise when escalation is safer than advocacy.

Working terms and boundaries

• This is a continuing full-time role with first-year gates at risk mapping, priority red-team reviews and regional capability assessment.
• The Director owns readiness standards and delegated recommendations; representation, settlement, litigation and reserved policy approval remain elsewhere.
• Annual remuneration combines fixed pay, target bonus and conditional deferred performance awards under normal governance.
• Hybrid work includes Frankfurt case forums and planned jurisdiction visits only where material factual evidence cannot be tested remotely.
• First-year completion requires reconciled priority records, resolved contradictions, usable response playbooks and independently capable regional leaders.

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 9 October 2026. Mandate reference TAX-PER-2026-FRA-37.