Ex-PwC, Dhruva Transfer Pricing professional discusses growing opportunities

• Himanshu Bhandari has 13+ years of Transfer Pricing experience at PwC, Dhruva, and now as a founding member of Aurtus Consulting. 
• He specializes in helping startups and MNCs design effective TP structures and global documentation strategies.
• We spoke to him about the growing career opportunities in Transfer Pricing, fueled by startups, GCCs, and cross-border transactions.

How has the role of transfer pricing evolved?

Over the years, Transfer Pricing (TP) has shifted from a simple compliance activity – just ticking the box – to a critical strategic function discussed in boardrooms.

Why? A major TP notice can quickly escalate and the implications are significant, and in some cases, even extend to reputation risk.

Culturally, I have noticed a shift among MNCs operating in India.

Earlier, companies aimed to keep margins thin in developing countries like India. Now, many are willing to retain higher profit margins here. This cultural shift has also been accompanied by an improvement in the quality of tax authorities’ TP assessments.

The tax office now asks more mature questions, leveraging global documents, databases, and literature.

As a result, transfer pricing has transitioned from being predominantly compliance-driven to more advisory-focused.

We now work extensively on Transfer pricing planning and strategy rather than just filing reports.

Businesses, particularly startups, are increasingly recognizing the importance of having robust TP models to avoid future disputes and ensure seamless global operations.

Investors, too, are paying closer attention to TP policies.

At what stage should companies and startups engage transfer pricing professionals?

Startups are indeed my favourite part of transfer pricing. I love engaging with founders, learning about their businesses, and helping them navigate cross-border challenges.

Startups should start thinking about transfer pricing the moment they plan to go global.

Whether they are setting up a subsidiary in Singapore, the US, or any other country, it’s essential to establish a basic TP framework early on.

Even a high-level analysis at the initial stage can prevent major structural changes later.

Investors are also increasingly asking startups about their TP policies because they directly impact tax liabilities and potential risks.

A well-thought-out TP model ensures that startups pay the right amount of tax in each jurisdiction while minimizing compliance risks.

Moreover, it reassures investors that the company is prepared for international expansion without unexpected tax disputes.

Also read: This CA built a Transfer Pricing Firm in a space dominated by Big 4s: A decade later, his triumph expands to the UAE.

What are the career opportunities in transfer pricing?

The growing complexity and strategic importance of transfer pricing have opened up tremendous career opportunities.

Unlike routine tax work, which is largely driven by legal principles, transfer pricing requires a deep understanding of the client’s business to set appropriate pricing structures.

This makes it a highly engaging and rewarding field for professionals interested in understanding business models and operations.

Globally, TP principles are fairly consistent, which creates opportunities for professionals to work across different countries.

I’ve seen many colleagues move internationally and thrive because of this global applicability.

In fact, several companies have set up Global Capability Centers (GCCs) in India to handle their TP compliance and documentation across multiple countries.

Are there significant transfer pricing job opportunities in GCCs?

The growth of GCCs in India is fueled by the country’s vast and diverse talent pool, spanning fields like finance, tax, technology, and supply chain management.

Initially concentrated in metro cities, GCCs are now expanding into tier-two and tier-three cities, driven by the availability of skilled professionals.

From a transfer pricing perspective, GCCs play a crucial role in managing global compliance.

Large multinational groups with operations in numerous countries need centralized teams to handle TP documentation and coordinate with consultants worldwide.

Setting up these teams in India allows them to streamline their operations and reduce costs while maintaining high-quality output.

This trend has significantly boosted the demand for TP professionals in India, especially in GCCs.