JOB DESCRIPTION

The Manager owns the day-to-day delivery of Transfer Pricing and international tax engagements: leading fieldwork, producing technically sound deliverables, and supervising a small team, while  working under a Senior Manager or Partner for client strategy and sign-off.

TRANSFER PRICING DOCUMENTATION AND COMPLIANCE

• Lead the preparation and review of Local File, Master File and CbCR (PMK 213/PMK.04/2016), applying ex-ante arm’s-length analysis.
• Run functional, industry and economic (CUP/TNMM/CPM/DEMPE) analyses and benchmarking studies, and review the work of Senior Associates and/ or Associates.
• Manage TP disclosures in the annual CIT return and related compliance calendar for a client portfolio.

TRANSFER PRICING AUDIT, OBJECTION AND APPEAL

• Lead client responses to DGT Transfer Pricing audit queries and formal tax audits (including under PMK 15/2025 timelines), preparing position papers and defense files.
• Draft and manage objection letters and appeal submissions (Tax Court) on Transfer Pricing adjustments, coordinating with legal counsel where needed.
• Represent the engagement team in meetings with tax auditors and objection or appeal reviewers.

APA AND MAP

• Prepare unilateral and bilateral APA applications and supporting economic analysis;  manage the APA negotiation timeline with the DGT. 
• Support MAP requests and case files for treaty-based double taxation relief,  coordinating with the Competent Authority process.

GMT (PILLAR TWO)

• Assist clients with GMT/QDMTT impact assessments and GloBE income computations under PMK 136/2024, including ETR modelling and top-up tax calculations. 
• Support GIR/DMTT/ UTPR return preparation and coordination with clients’  accounting teams on PSAK 46/IAS 12 disclosures.

ADVISORY AND ENGAGEMENT MANAGEMENT

• Advise clients on Transfer Pricing planning, business restructuring and intercompany policy design to maintain arm’s-length positions. 
• Manage engagement economics: scoping, budgeting, timelines, and staffing across concurrent engagements. 
• Coach, train, and review the work of Associates and/ or Senior Associates; contribute to proposals and technical training materials.

JOB REQUIREMENTS

• Bachelor’s degree in Accounting, Economics, Finance, Law, or a related field; a  Master’s degree or Brevet C is an advantage. 
• 5–7 years of relevant experience in transfer pricing or international tax, with a significant portion in a Big 4 or reputable tax advisory firm, or the DGT’s Transfer Pricing function,  and have minimum 3 years experience in a managerial position. 
• Working knowledge of PMK 172/2023 (Transfer Pricing), PMK 213/2016 (Transfer Pricing documentation/CbCR), PMK 15/2025 (tax audit), PMK 136/2024 (GMT), and the  OECD Transfer Pricing Guidelines.

• Demonstrated experience across at least two of: Transfer Pricing documentation, Transfer Pricing audit  defense, objection/appeal, APA, or MAP. 
• Strong economic or financial analysis skills (CUP, TNMM, CPM, DEMPE, benchmarking  databases such as Bloomberg/Orbis/Capital IQ). 
• Proven ability to manage multiple engagements concurrently, including budgeting,  timelines, and staffing. 
• Experience supervising, reviewing, and developing junior staff (Associate or Senior Associate level). 
• Strong written and verbal communication in both Bahasa Indonesia (formal legal register) and English, including drafting objection or appeal letters and client-facing reports. 
• Strong client-facing and stakeholder-management skills, including representing clients before tax auditors and reviewers. 
• Exposure to industries with active Transfer Pricing scrutiny (extractive industries, financial  services, manufacturing) is an advantage.