Advance Pricing Submission Recovery Director

The mandate

The interim Director will recover a defined advance-pricing submission whose facts, economic analysis, supporting records and work ownership are not yet controlled against the procedural timetable. The appointee must begin within three weeks, establish a truthful readiness position and move the case to an authority-ready or consciously deferred decision. The assignment does not guarantee authority acceptance or agreement.

The first fifteen business days will reconcile intended covered transactions, years, parties, eligibility, deadlines, agreements, functional facts, calculations and prior correspondence. Gaps will be classified as fatal, remediable, judgmental or dependent on an authority. The Director must prevent schedule pressure from converting missing facts into definitive assertions.

Temporary authority covers recovery sequencing, evidence gates, factual-owner assignments, adviser briefs and routine submission decisions within delegation. Formal filing, representations, negotiations, material concessions and policy changes remain reserved. Broader documentation refresh, unrelated audits and contract redrafting are outside scope.

Handover requires the permanent case leader to chair one submission-readiness review and one authority-question simulation. Exit is accepted when the dossier is complete or a deferral decision is documented, procedural rights are protected, contradictions are resolved or owned, and the Global Transfer Pricing Head signs the case record and forward engagement plan.

What you will own

• Reconcile covered transactions, parties, periods, eligibility, procedural dates and current authority expectations into one case plan.
• Establish a fact record covering functions, assets, risk control, decision conduct, agreements and changes across proposed years.
• Validate economic methods, tested results, forecasts and critical assumptions against controlled source evidence.
• Identify contradictions among proposed submission, documentation, filings, contracts and actual conduct before authority contact.
• Direct narrowly scoped adviser or valuation work with approved facts, decision questions and acceptance standards.
• Prepare an authority-ready submission architecture and response index without overstating facts or likely agreement.
• Test the permanent leader through a formal readiness review and simulated challenge to the weakest material assumption.
• Transfer an accepted dossier, procedural calendar, issue log, reserved decisions and authority-engagement plan.

Candidate qualifications

• Seventeen or more years of transfer-pricing practice, with direct senior leadership of at least one unilateral and one bilateral advance-pricing submission.
• An APA submission you recovered, narrowed or deferred because factual or economic readiness was weaker than reported.
• Deep command of eligibility, covered transactions, functional analysis, method selection, critical assumptions and authority process.
• Evidence of resolving inconsistency between proposed covered facts and contracts, filings or observed conduct.
• Experience directing economists, valuers or counsel through precise scope while retaining internal ownership.
• Ability to recommend conscious deferral rather than force a weak submission to meet an internal date.
• A handover example using a live readiness forum and authority-question simulation.

Working terms and boundaries

• The recovery occupies five working days weekly for nine months; no more than six extra weeks are available, and only when authority timing prevents the successor from completing transfer.
• The interim controls recovery and delegated submission readiness, while filing, representation, negotiation and concession remain reserved.
• Broader documentation, unrelated audit defence and contract redrafting are excluded.
• Singapore presence is required through fact recovery and readiness review, with approved travel for material factual validation.
• Completion requires an accepted or consciously deferred dossier, protected rights, successor operation and signed residual ownership.

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-SIN-62.