Transfer Pricing Senior Manager (Tax)

At BDO Thailand our Tax & Legal Team is focused on providing holistic support for our clients.

We work with large MNCs and SMEs to provide them support on tax and corporate legal matters.

We are a full-service firm providing support from setting up of an entity, ensuring companies understand and comply with the local regulation, and even support when they plan to downsize or liquidate.

We strongly believe in supporting our people grow and help them become better leaders. 

As a Senior Manager you will operate as a key part of the leadership team within the line of service as well as across the practice. You will provide quality client services, meeting business objectives, lead business development, lead the line of service and the teams in their development, and be proactively involved with across the practice in these areas.

Specific responsibilities of the role include:

• Lead transfer pricing engagements for multinational clients, including the preparation and review of transfer pricing documentation in both English and Thai language (master file, local file, country-by-country reports, transfer pricing disclosure forms, benchmarking studies, policy reports and transfer pricing agreements).
• Provide strategic transfer pricing advice to multinational companies on intra-group transactions, ensuring compliance with Thai transfer pricing regulations and international guidelines.
• Develop and implement transfer pricing strategies for M&A transactions, supply chains, and other business restricting models.
• Basic understanding of international tax matters, focusing on cross-border transactions, double tax treaties, and Base Erosion and Profit Shifting initiatives.
• Basic understanding of OECD’s pillar 2 initiatives and support clients in preparing for the implementation of Pillar 2, including assessing the impact on their effective rates and compliances processes.
• Coordinate with other teams to mitigate transfer pricing risks.
• Cross-services collaboration to ensure holistic approach on client engagements.
• Efficient and effective delivery of engagement on time and on budget, and in compliance with quality and risk standards including ISQC1 and firm policies and procedures, in accordance with exceptional client service

It is expected you would have a highly competent understanding / knowledge of the following technical areas:

• Thai Revenue Code, including corporate income tax, personal income tax, specific business tax, value added tax and stamp duty 
• Thailand’s tax and non-tax incentive regimes, including BOI and IBC
• Thailand’s income tax treaties 
• OECD international tax guidelines including BEPS
• Assisting clients with tax audits
• Experience of preparing Transfer Pricing documentation, including benchmarking, Local File and Master File
• Tax structuring for M&A transactions and internal reorganizations, including tax due diligence 

• Work effectively as part of a team as a leader, and active development of knowledge sharing and thought leadership
• Motivate, encourage and actively bring the best out of the team and each member
• Lead business development activities and ensure active on social media platforms
• Building and maintaining a network internally and externally, and staying aware of industry trends, and effective communication of industry related matters
• Lead opportunities for improvement and development of solutions internally and externally, including digital solutions
• Recruitment, and implementation of firm coaching and training strategy for the line of service
• Development of thought leadership and participation in networking events
• Commercial negotiation, opportunity identification, opportunity conversion and increasing business acumen. 

Minimum

• 10-12 years’ experience in relevant field
• University degree
• Post graduate qualification
• Fluent in Thai language
• Good English skills

Desirable

• Advanced English language skills

• Become a part of an exciting and fast-growing business and play an important role in it's growth and success
• Great long term career opportunity
• Be empowered to get creative and think outside the box