Residual Profit Split Design Director

The mandate

This consulting assignment will design and validate a residual profit-split method for a defined set of highly integrated controlled transactions. The bounded problem is to establish whether unique contributions and shared risk control make a one-sided method unreliable, then translate the accepted economic logic into data, calculations, documentation and controllable execution. The project cannot assume profit split is the answer before factual testing.

Milestone one, due at month two, is an accepted contribution and transaction delineation record. Milestone two, due at month four, is the method-selection paper comparing credible alternatives and stating why each is accepted or rejected. Milestone three, at month seven, is a validated model specification, data dictionary and sensitivity report.

Milestone four, due at month nine, is a production-representative pilot reconciling combined profit, routine returns, allocation factors and entity outcomes to controlled sources. The final milestone is an accepted methodology, operating handbook, documentation pack and residual-risk register. Technical acceptance belongs to the Global Transfer Pricing Head; model-control acceptance belongs to the appointed finance-data owner.

The client will provide transaction records, agreements, segmented financials, personnel and decision evidence, existing policies and factual-owner access. Acceptance requires coherent delineation, justified profit base, independently understandable allocation factors, reproducible calculations and resolved critical sensitivities. Legal drafting, return submission, controversy defence and system build are excluded.

What you will own

• Delineate the selected transactions through actual functions, assets, risk control, integration, contributions and economically relevant circumstances.
• Test whether reliable one-sided methods or price methods exist before recommending use of residual profit split.
• Define the combined profit or loss, accounting perimeter, routine return logic and treatment of exceptional or pass-through items.
• Design allocation factors that reflect relative value contribution, can be measured consistently and do not reward scale unrelated to contribution.
• Quantify sensitivity to profit-base definitions, routine-return assumptions, factor weights, loss years and material data uncertainty.
• Build model controls covering source lineage, transformation, versioning, approval, change triggers and reconciliation to entity results.
• Execute a pilot with production-representative data and resolve defects before recommending first operational use.
• Deliver accepted technical and operating artifacts, training evidence, explicit limitations and ownership of subsequent recalibration.

Candidate qualifications

• At least 17 years in transfer pricing economics, including Director-level responsibility for profit-split analysis in highly integrated arrangements.
• A case where you rejected profit split after factual or data testing, or materially changed its design before implementation.
• Advanced command of transaction delineation, unique contributions, risk control, combined profit, routine returns and allocation-factor design.
• Evidence of linking allocation factors to demonstrable value contribution rather than choosing measures for data convenience.
• Experience modelling and explaining loss outcomes, volatile residual profit and sensitivity without hiding limitations.
• Ability to reconcile economic models to segmented accounting and create controls usable by permanent finance teams.
• Completion record across multi-stage economic projects with distinct technical and data-control acceptance.

Working terms and boundaries

• The ten-month engagement requires four days a week and releases payment through five formally accepted deliverables.
• Transfer Pricing accepts delineation and method; the finance-data owner independently accepts model lineage, reconciliation and operating controls.
• Complete agreements, segmented financials, personnel evidence, policy records and owner access are client dependencies with dated delivery points.
• Legal drafting, filing, controversy representation and system development are excluded and require separate written variation.
• Final acceptance requires a reproduced pilot, cleared critical defects, supported allocation factors, trained operators and signed residual limitations.

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-PAR-32.