Transfer Pricing Audit Response Director

The mandate

The interim Director will take temporary executive control of a transfer-pricing audit response whose factual, economic and procedural workstreams are not yet operating through one record. The appointee must start within three weeks, protect response rights and ensure submissions are consistent with contracts, conduct, calculations and prior filings. The assignment cannot promise a dispute outcome.

The opening fifteen business days will reconcile information requests, deadlines, covered transactions, years, local documentation, agreements, functional facts, financials and authority correspondence. Each gap will be classified by response urgency, technical consequence and ability to remedy. Assertions unsupported by contemporaneous fact will not be promoted to certainty for response convenience.

Temporary authority includes case sequencing, evidence standards, work allocation, response quality gates and scoped adviser commissioning within delegation. Formal representation, settlement, litigation, material concessions and accounting conclusions remain reserved. New pricing policy, unrelated compliance and legal contract changes sit outside the assignment.

Handover begins when the permanent case leader chairs the first complete response review. Exit requires that successor to lead a second authority cycle and defend the weakest material issue in a simulated challenge. Complete chronologies, evidence indexes, economic files, procedural calendars, reserved decisions and residual ownership must be accepted before the interim leaves.

What you will own

• Reconcile the audit scope, transactions, periods, authority questions, deadlines, extensions and response owners into one case plan.
• Build factual chronologies covering functions, assets, risk control, agreements, decision conduct and changes across audited years.
• Tie economic analyses and tested results to controlled segmented financials, filings and actual adjustment entries.
• Identify contradictions among submissions, local files, master positions, contracts and operational evidence before authority response.
• Return drafts that over-answer, use stale facts, hide contrary evidence or fail to address the authority's precise concern.
• Direct external economists or counsel through approved facts, narrow questions, budgets and internally accepted outputs.
• Prepare the successor through two live response cycles and a red-team examination of the most exposed issue.
• Transfer accepted case files, procedural rights, open questions, accounting interfaces and the next authority-engagement plan.

Candidate qualifications

• At least 17 years in transfer pricing and controversy, including Director-level response leadership in a major authority audit.
• A response you materially changed after discovering contradiction between documentation, contract, conduct or financial result.
• Deep command of transaction delineation, methods, comparability, segmented financials, adjustments and audit procedure.
• Evidence of constructing truthful factual records where contemporaneous evidence was incomplete.
• Experience governing external economists and counsel while retaining internal case decisions and budget control.
• Ability to preserve procedural rights and accounting interfaces without assuming settlement or reporting authority.
• A successful interim transfer involving live successor-led authority responses.

Working terms and boundaries

• The eleven-month engagement is five days a week; a one-month extension requires an external deadline blocking successor handover.
• The interim controls response process and delegated quality gates; representation, settlement, litigation and accounting remain reserved.
• New pricing policy, unrelated filing work and contract amendment are excluded.
• São Paulo presence is required through fact reconstruction and first authority cycle, with travel approved for critical evidence.
• Completion requires protected rights, coherent records, successor-led responses and signed ownership of every residual issue.

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 10 October 2026. Mandate reference TAX-INT-2026-SAO-66.