Transfer Pricing Benchmark Governance Director

The mandate

This project will establish a governed benchmark-study framework for selected recurring transfer-pricing methods. The defined problem is inconsistent decisions about tested party, search strategy, comparability, adjustments, ranges and refresh, leaving technically similar studies difficult to compare or reproduce. The assignment must deliver usable decision rules and validated studies, not a library of undifferentiated searches.

Milestone one, due in week four, is a study inventory and risk classification covering purpose, method, period, source, preparer, factual owner and controversy use. Milestone two, at month two, is the approved search and review protocol. Milestone three, at month four, consists of reworked or validated priority studies with complete decision logs and sensitivities.

The final milestone at month five is a benchmark governance handbook, reviewer calibration set, refresh calendar and accepted residual-exception register. Technical acceptance belongs to the Global Transfer Pricing Head; reproducibility and data-control acceptance belong to the nominated tax-operations owner.

The client will supply existing studies, databases under valid licence, functional analyses, segmented results, agreements and reviewer access. Acceptance requires reproducible searches, fact-consistent tested-party choices, reasoned inclusion and exclusion, supported adjustments and clear refresh triggers. New policy design, functional interviews outside selected studies, documentation production and controversy representation are excluded.

What you will own

• Catalogue recurring benchmark studies and classify them by method, materiality, factual volatility, controversy exposure and refresh need.
• Define minimum evidence for tested-party selection, geographic and industry scope, search terms, screening, multi-year data and loss treatment.
• Require inclusion and exclusion decisions to be reproducible from database output, public information and the approved functional profile.
• Establish when working-capital, accounting, geographic or other comparability adjustments improve reliability rather than create false precision.
• Validate selected studies through independent rerun, financial reconciliation and sensitivity to plausible alternative screens.
• Create rules for annual update, full refresh, event-triggered reconsideration and use of a study across more than one jurisdiction.
• Calibrate permanent reviewers using borderline candidates and require documented reasoning where reasonable judgments differ.
• Deliver accepted protocols, validated study files, decision logs, training results and ownership of residual exceptions.

Candidate qualifications

• At least 15 years in transfer-pricing economics, including Director-level ownership or review of benchmark-study portfolios.
• A search result you rejected despite statistical attractiveness because its functional or accounting comparability failed.
• Advanced command of tested-party choice, database strategy, quantitative and qualitative screening, adjustments, ranges and refresh practice.
• Evidence of reproducing a prior study and identifying an undocumented judgment that materially changed the arm's-length result.
• Experience reconciling tested-party financials to controlled source records before statistical analysis.
• Ability to distinguish useful comparability adjustment from model complexity unsupported by available data.
• Fixed-project completion through separate technical and data-control acceptance and reviewer calibration.

Working terms and boundaries

• The five-month engagement uses three days a week and pays through four accepted milestones rather than study volume.
• Transfer Pricing accepts method and comparability; tax operations separately accepts reproducibility, source control and refresh governance.
• Existing studies, licensed data, functional analyses and financial records are scheduled client dependencies.
• Policy redesign, broad interviews, documentation drafting and controversy representation are excluded and require written variation.
• Final acceptance requires reproduced priority studies, resolved critical defects, calibrated reviewers and assigned residual exceptions.

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 8 October 2026. Mandate reference TAX-CON-2026-BOM-44.