Manager Transfer Pricing & International Tax

At BCL, we dont hire for roles — we hire for impact. BCL India (Balakrishna Consulting LLP) and BCL Globiz (UAE) are a growing professional services firm with a specialist Transfer Pricing and International Tax practice spanning India, UAE, UK, US, Singapore, and Europe. We work with founder-led businesses, MNCs, and family offices — and we are built for the ambitious.

This role sits at the centre of our practice. You will own delivery, grow the business, lead a team, build our global TP capability, and represent BCL in front of regulators, clients, and peers. If that sounds like a lot — it is. If it sounds exciting — read on.

WHAT YOU WILL DO

TP Compliance & Documentation

• ▸ Lead end-to-end TP compliance for all clients — TP Study Reports, Local Files, and Master Files across
• India and UAE
• ▸ Prepare and review UAE TP Disclosure Forms under Cabinet Decision No. 97/2023
• ▸ Manage Form 3CEB, Accountants Report, and related Indian TP filings within statutory timelines
• ▸ Build and maintain standardised benchmarking databases and comparable sets for India and UAE
• engagements
• ▸ Own quality control across all compliance deliverables — nothing goes out without your sign-off

TP Litigation & Representation

• ▸ Handle Transfer Pricing disputes at TPO, DRP, and ITAT levels — from drafting written submissions to
• appearing in hearings
• ▸ Prepare and present detailed technical positions, economic analyses, and comparability arguments
• ▸ Manage Safe Harbour applications, Advance Pricing Agreement (APA) documentation, and MAP
• proceedings
• ▸ Liaise with senior counsel, advocates, and client management on contested matters

TP Advisory & Complex Structuring

• ▸ Lead high-complexity advisory mandates — business restructurings, IP migrations, intercompany
• financing, value chain analyses
• ▸ Design and review intercompany agreements, cost-sharing arrangements, and service fee structures
• ▸ Advise on BEPS-aligned frameworks — Pillar Two applicability, CbCR, and substance requirements
• ▸ Deliver UAE TP advisory including DMCC QFZP structuring, DIFC entity analysis, and cross-border
• invoice structuring

Business Development & B2B Partnerships

• ▸ Drive B2B growth — identify, approach, and onboard law firms, accounting firms, and consultancies as
• TP referral or white-label partners
• ▸ Build scalable TP delivery capability that partner firms can plug into — standardised templates
• turnaround SLAs, and pricing models
• ▸ Support partner pitches and client proposals; represent BCL at industry events, conferences, and
• roundtables
• ▸ Own a personal BD pipeline and contribute to the practices ₹3.5 Cr+ annual revenue target

Global TP Capability Building

• ▸ Build BCLs expertise in TP regulations across key jurisdictions — US (Section 482), UK (HMRC OECD
• alignment), Singapore, UAE, and key European markets
• ▸ Create jurisdiction-specific knowledge resources, advisory frameworks, and compliance checklists for
• internal use and client delivery
• ▸ Stay ahead of OECD developments, BEPS Action Plans, and country-specific TP rule changes — and translate them into practice updates

Team Leadership & Knowledge Management

• ▸ Mentor and train a team of Associates and Junior Managers in TP technical skills, client communication
• and professional standards
• ▸ Conduct structured internal training sessions, case study reviews, and technical knowledge-sharing
• programmes
• ▸ Write high-quality blogs, technical articles, and thought leadership content on a regular basis — for
• LinkedIn, BCLs website, and external publications

Technology & Process Excellence

• ▸ Champion AI and automation adoption within the TP practice — streamline benchmarking,
• documentation drafting, and compliance workflows
• ▸ Work with BCLs automation lead to build technology-assisted processes that improve quality and
• reduce turnaround time
• ▸ Explore and pilot TP-specific tools, databases, and AI-assisted research platforms

WHO WE ARE LOOKING FOR

Qualifications & Experience

• ▸ Chartered Accountant (CA) — mandatory
• ▸ 6–9 years of Transfer Pricing experience in a Big 4, leading mid-tier firm, or specialist TP boutique
• ▸ Hands-on experience with Indian TP litigation — TPO, DRP, and ITAT proceedings
• ▸ Strong working knowledge of OECD TP Guidelines and BEPS framework
• ▸ UAE TP experience (post-CT Law) preferred; willingness to build UAE expertise is essential
• ▸ Track record of managing client relationships independently, not just supporting seniors

Skills & Attributes

• ▸ Sharp technical writer — able to draft clean, persuasive TP documentation and submissions
• ▸ Excellent communicator — equally comfortable presenting to a TPO as to a founder-client
• ▸ Business development mindset — you see every conversation as an opportunity to build a relationship
• ▸ Intellectually curious — keeps up with OECD developments, case law, and global TP trends without
• being prompted
• ▸ Tech-forward — willing to experiment with AI tools and process automation
• ▸ Growth-oriented — takes ownership, drives outcomes, and doesnt wait to be told what to do