Senior Director Transfer Pricing — Software Value Creation and Agreement Governance

The mandate

A software-development group is creating a senior-director transfer-pricing role after regional growth changed how product development, customer support and commercial decisions are distributed between entities. Intercompany agreements describe an earlier operating model and no longer provide a complete account of actual value creation. This open-ended appointment begins with a twenty-four-month agenda to refresh policy, strengthen evidence and govern agreement execution. The executive must establish positions that can withstand scrutiny because they reflect conduct, not because the documentation is extensive or the labels sound familiar.

You will examine who makes material development decisions, controls risk, performs specialist work and bears the economic consequences when a product investment fails. The analysis must connect interviews, governance records and financial data without assuming that the location of expenditure alone determines entitlement to return. Advance-pricing agreement options need practical evaluation of scope, evidence and execution implications. An agreement that secures certainty for one transaction but leaves adjacent charges or changing functions unexplained may not solve the group's underlying governance problem.

The role leads nine specialists and coordinates entity-finance owners. You can set documentation methods, approve routine intercompany charges under authorised policy and require operating teams to resolve missing functional evidence. The global tax vice president approves new pricing policy, agreement strategy and material settlement positions. Regional finance ensures booked charges reconcile; legal manages contractual execution. You will create review triggers for changes in product ownership, specialist staffing or decision rights, so a supposedly compliant year-end adjustment does not conceal a policy whose assumptions have become obsolete.

The opening programme should produce an evidence-backed functional map, renewed agreement governance and a transparent cycle connecting forecast charges to actual outcomes. Later responsibility includes controversy support, reviewer development and reassessment when the software business changes. Bengaluru is the base, with travel scheduled around evidence gathering and agreement discussions. The senior director owns regional transfer-pricing policy and organises specialist judgement across entities, maintaining an honest distinction between technical certainty and unresolved factual risk when advising the group's authorised decision makers.

What you will own

• Construct a functional value-creation map from decision records, interviews and operating evidence, identifying where contractual allocations of risk or responsibility diverge from the conduct of development and commercial teams.
• Decide documentation and review standards for routine charges, making source evidence and policy assumptions visible enough that entity controllers can reconcile accounting entries without inferring the intended economic treatment.
• Recommend advance-pricing agreement scope using transaction materiality, factual stability and certainty needs, explaining unresolved adjacent arrangements and execution obligations before the global tax vice president selects a strategy.
• Establish operating-model change triggers for product ownership, specialist capability and decision rights, requiring timely tax reassessment rather than assuming the annual documentation cycle will capture every material shift.
• Build the forecast-to-actual intercompany charge bridge with finance owners, separating approved economic adjustments from data errors and recording how deviations affect the defensibility of the underlying pricing position.
• Develop specialist reviewers and entity liaisons through worked evidence assessments, strengthening their ability to challenge unsupported functional narratives without substituting anecdote or contractual wording for observed business conduct.

Candidate qualifications

• Offer twelve to eighteen years of international-tax experience with substantial transfer-pricing responsibility in software or technology services. Describe a position you revised because actual decision making differed from intercompany documentation. Explain the evidence you gathered, the technical reasoning and the governance change made, rather than presenting a benchmarking study or an agreement outcome without showing your personal contribution.
• Bring professional accounting and tax depth, normally through Chartered Accountancy or a comparable qualification, and practical understanding of functional analysis, agreement strategy and controversy support. You must interrogate who controls risk and what evidence supports that conclusion, recognise uncertainty in interview narratives and connect financial charges to the actual transactions being analysed rather than accepting labels as proof.
• Demonstrate experience with advance-pricing or bilateral agreement processes, including preparation of coherent facts and management of implementation obligations. The requirement is thoughtful scope and evidence judgement, not a claim that certainty can always be obtained. Show how you handled evolving functions, incomplete data or adjacent transactions that did not fit neatly into the proposed agreement's defined perimeter.
• Evidence regional leadership with finance, legal and product stakeholders, plus the ability to develop reviewers who can apply a method consistently. You should have established change triggers, maintained secure functional evidence and corrected a narrative when business conduct contradicted it. The expanded role requires calm challenge to powerful operating sponsors and clear escalation of material policy choices without drifting into product or commercial executive authority.

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 CVU-PER-2026-IND-019.