Transfer Pricing Policy Reconstruction Director

The mandate

This consulting assignment will replace a collection of disconnected transfer-pricing positions with one decision-ready policy architecture. The defined problem is that legal agreements, functional reality, charging mechanics and documentation do not consistently express the same allocation of value. The work is not an open-ended review of every tax matter; it must produce an implementable policy set and evidence that the first controlled cycle operates as designed.

Milestone one, due four weeks after access begins, is a fact-and-gap record covering material transaction families, functions, assets, risks, agreements, data paths and current controversy exposure. Milestone two, due at the end of month three, is a policy blueprint containing tested pricing methods, decision rights, exception routes and accounting requirements. Both artifacts require written factual confirmation from named internal owners.

Milestone three, at the end of month five, comprises executed implementation packs for the selected transaction families: calculation specifications, agreement change instructions, posting controls, true-up rules and documentation evidence. Milestone four, due in month six, is a witnessed first-cycle report, residual-risk register and operating handbook. Acceptance belongs jointly to the Global Head of Tax and the designated finance-control owner.

The client will provide transaction data, legal agreements, management access, prior studies, controversy records and a cross-functional working team. Acceptance requires reconciliation of policy to actual postings, sign-off of factual profiles and closure or explicit ownership of all high-risk exceptions. Legal drafting, tax-return preparation, systems procurement and defence of new audits are excluded unless separately commissioned.

What you will own

• Catalogue material controlled transactions and reconcile contractual descriptions to observed functions, assets, risks, decision conduct and ledger flows.
• Diagnose contradictions between local files, master positions, intercompany agreements, calculation models and the way charges are actually booked.
• Design a policy hierarchy that identifies the governing principle, permitted method, tested party, profit-level indicator, data source and approval authority for each transaction family.
• Define an exception protocol covering new transactions, loss outcomes, data failure, extraordinary events and departures from the approved range.
• Translate policy into calculation specifications, posting calendars, true-up logic, evidence retention and accountable finance-control checks.
• Facilitate factual validation workshops while documenting unresolved disagreement rather than manufacturing consensus for completion.
• Observe the first controlled calculation cycle and trace selected results from source data through invoice or journal to reporting and documentation.
• Submit an acceptance pack with tested artifacts, stakeholder sign-offs, residual exposures, excluded matters and a sequenced ninety-day sustainment plan.

Candidate qualifications

• At least 16 years in international tax and transfer pricing, including Director-level responsibility for redesigning a policy across several transaction families and jurisdictions.
• A completed example showing reconciliation of functional analysis, legal terms, economic method and operational postings, with acceptance evidence rather than a policy report alone.
• Advanced command of OECD transfer-pricing principles, method selection, comparability, risk control, financial transactions, services, intangibles and year-end adjustments.
• Experience converting technical policy into accounting specifications and controls that finance teams can operate without continuous tax-specialist intervention.
• Evidence of handling factual disagreement among tax, legal, finance and business leaders while preserving an auditable decision record.
• Ability to define defensible exclusions, dependencies and change-control rules so a six-month engagement does not expand into general tax support.
• Independence from prior authorship of the positions under review, with all relevant advisory relationships disclosed before access.

Working terms and boundaries

• The engagement runs six months at four days a week and is governed by four acceptance-linked milestones rather than elapsed consulting time.
• The Global Head of Tax accepts technical policy artifacts; the finance-control owner separately accepts posting, reconciliation and operating-control evidence.
• The client must provide complete data extracts, agreements, prior studies, owner access and a working team according to the agreed dependency calendar.
• Legal drafting, filing production, system acquisition and representation in new controversy proceedings remain outside scope; changes require a priced written variation.
• Final acceptance requires a witnessed first cycle, resolved critical defects, signed factual profiles and named ownership for every residual exception.

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-AMS-04.