Transfer Pricing & International Tax Manager

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

TP Documentation & 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/Associates.
• Manage TP disclosures in the annual CIT return and related compliance calendar for a client portfolio.

TP Audit, Objection & Appeal

• Lead client responses to DGT TP 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 TP adjustments, coordinating with legal counsel where needed.
• Represent the engagement team in meetings with tax auditors and objection/appeal reviewers.

APA & 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 & Engagement Management

• Advise clients on TP 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/Senior Associates; contribute to proposals and technical training materials.

• 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/international tax, with a significant portion in a Big 4 or reputable tax advisory firm, or the DGT's TP function, and have minimum 3 years experience in a managerial position.
• Working knowledge of PMK 172/2023 (TP), PMK 213/2016 (TP documentation/CbCR), PMK 15/2025 (tax audit), PMK 136/2024 (GMT), and the OECD Transfer Pricing Guidelines.
• Demonstrated experience across at least two of: TP documentation, TP audit defense, objection/appeal, APA, or MAP.
• Strong economic/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/Senior Associate level).
• Strong written and verbal communication in both Bahasa Indonesia (formal legal register) and English, including drafting objection/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 TP scrutiny (extractive industries, financial services, manufacturing) is an advantage.

• Competitive salary package
• Religious Holiday Allowance
• Medical Reimbursement for out-patient
• Third-party Insurance for in-patient
• Income tax art. 21 allowance
• Hourly-based project incentive