Transfer Pricing Documentation Defensibility Director

The mandate

The Director will own the factual and analytical defensibility of transfer-pricing documentation as a continuing global discipline. The job is not to maximise the volume of local files. It is to ensure that material controlled transactions are described consistently with contracts, conduct, calculations and reported results, and that country-specific work remains connected to an approved global position.

The first quarter will establish the transaction and documentation population, materiality logic, factual certification route and risk-based review plan. The leader will identify contradictions among master narratives, local analyses, agreements, functional reality and ledger outcomes. Templates may support consistency, but no jurisdictional file may rely on generic assertions where local facts or law require a different analysis.

Authority includes setting documentation standards, assigning factual owners, returning deficient files, approving routine positions within delegation and escalating policy or controversy implications. Local authorised officers retain filing or submission rights; policy owners retain reserved method decisions; legal owners retain contracts. The Director must coordinate those responsibilities without consolidating them improperly.

At month twelve, every material transaction family should have a governed factual source, a reconciled economic result and a documented change trigger. Priority local files must be contemporaneous and challenge-ready, review effort must follow risk, and regional leaders must be able to defend the record without reciting central language they cannot substantiate.

What you will own

• Establish a complete documentation matrix linking controlled transactions, jurisdictions, thresholds, due dates, policy owners, factual certifiers and review authority.
• Define a factual certification standard covering functions, assets, risk control, decision location, agreements, personnel and changes during the period.
• Reconcile documented tested results to approved calculations and ledger outcomes, requiring explanations for ranges, losses and year-end adjustments.
• Direct risk-based deep reviews where materiality, controversy history, unusual outcomes or factual change makes template reliance unsafe.
• Return files containing unsupported claims, inconsistent methods, stale benchmarks or narratives that conflict with observable conduct.
• Create change triggers for restructurings, leadership movement, new transactions, contract changes, persistent losses and altered risk control.
• Govern external documentation providers through agreed evidence, issue logs, quality measures and internal acceptance rather than delivery count.
• Build regional reviewers through calibrated case files, red-team challenge and observed defence of locally owned facts.

Candidate qualifications

• Chartered Accountant or equivalent qualification and at least 16 years in transfer pricing, including Director-level documentation governance across numerous jurisdictions.
• A documentation contradiction you found between policy, contract, functional conduct or booked result, and the correction you drove.
• Strong command of functional analysis, method selection, comparability, financial segmentation, tested results and contemporaneous-documentation principles.
• Evidence of designing a risk-based review that reduced low-value production while strengthening the most exposed files.
• Experience requiring senior factual owners to certify conduct and changes rather than allowing tax teams to infer them retrospectively.
• A case where you rejected an external provider's technically polished file because its evidence could not withstand examination.
• Demonstrated development of regional reviewers able to defend local facts under authority challenge.

Working terms and boundaries

• This permanent full-time appointment has first-year gates at population validation, priority-file review and completion of one documentation cycle.
• The Director sets documentation and evidence standards; formal submission, reserved policy choices and legal-agreement approval remain separately authorised.
• Annual remuneration combines fixed pay, target bonus and conditional restricted-share or cash-settled long-term awards.
• Hybrid work includes Bengaluru review forums and scheduled travel to test material factual profiles where remote evidence is inadequate.
• First-year completion requires a reconciled matrix, certified facts, accepted priority files, live change triggers and independently capable regional reviewers.

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-BLR-29.