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Transfer Pricing Audit (TPA) Adviser

Australia Indonesia Partnership for Economic Governance (AIPEG)
Consulting Opportunity in the Government of Indonesia Directorate General of Taxes – Jakarta (4 months full time)
Transfer Pricing Audit (TPA) Adviser
The Australia Indonesia Partnership for Economic Governance (AIPEG) is an Australian Government-funded project assisting Indonesia to undertake economic and financial policy reforms. Norton Rose Fulbright, the Managing Contractor, is seeking applications for a DMS Adviser. The duration of the appointment will be approximately 4 months fulltime.
The TPA Adviser will work together with other advisers providing support for TP issues in areas of tax technical advice, dispute resolution and economic analysis to develop ‘end to end’ risk based capability building approaches. Deficiencies in TP skilling and knowledge required to undertake TP audits so that DG Taxes staff are better able to execute this aspect of audit functions will also be addressed.
DG Taxes has specifically requested AIPEG continued support in this area to assist DG Tax to introduce a risk based TP program using international best practice and to assist in the design and implementation of the audit processes and skilling necessary to support this program.
The successful candidate will be expected to have significant experience, appropriate qualifications, skills and attributes relevant to tax administration and compliance improvement, in particular. More specifically, the TPA Adviser should be able to demonstrate the following qualifications, skills, attributes and personal qualities:
Selection Criteria
Qualifications and experience:
  • A degree in law, accounting or economics or other formal qualifications and experience (at least 5 years) relevant to the services to be provided;
  • A good understanding of the risk indicators and principles that can be applied to improve the case selection techniques in relation to TP cases;
  • knowledge and experience in applying TP methodologies to successfully resolve complex TP issues;
  • Sound ability to analyse TP documentation and use economic analysis and other rationale to identify and resolve TP issues; and
  • Ability to provide training/capacity development.
Desirable:
  • Experience in all aspects of TP risk management within a tax administration.
Personal attributes:
  • Strong relationship management skills, particularly in dealing with senior government officials;
  • Ability to operate effectively and sensitively in a cross-cultural environment;
  • Strong professional leadership skills and capacity to coach and advise senior and junior staff;
  • High level communication skills and ability in written and spoken English; and
  • Strong personal drive, initiative and a desire for continuous improvement.
Desirable:
  • Consulting experience in Indonesia or a developing country;
  • Fluency or some ability in Bahasa Indonesia.
Short-listing Questions 
  1. Provide examples of types of transfer pricing issues and risks that you have investigated in your role as an auditor, including how you detected these items.
  2. Describe some approaches and methodologies you have used to investigate and resolve these transfer pricing issues.
  3. In the cases you have investigated, what were the most contentious or problematic issues to be resolved with the taxpayer and what strategies and approaches did you use to reach an outcome?
  4. What do you anticipate as some possible challenges when investigating and resolving transfer pricing risks in a developing country like Indonesia?


A copy of the Terms of Reference (TOR) may be obtained by writing toprocurement@aipeg.or.id or downloaded from www.aipeg.or.id.
Applicants should submit a CV, a written response which clearly addresses the selection criteria and a short statement addresses each of the short-listing questions listed above to: procurement@aipeg.or.id no later than 11.59 pm (Jakarta time) Sunday, 27 April 2014. The statement addressing the short-listing questions should not exceed 500 words per question.
Please put the position title as the subject of your email.
Failure to submit the complete set of applications may result in your application being rejected.
REMUNERATION:
The remuneration will be set within the Adviser Remuneration Framework (ARF) which can be found on the DFAT website (http://aid.dfat.gov.au/Publications/Documents/adviser-remuneration-framework.pdf). Remuneration may be set up to a level of Discipline Group D, Level 3, depending on the adviser’s skills and experience.
Selection will be made in accordance with Government of Australia procurement rules.  Norton Rose Fulbright is an equal opportunity employer.
Australian Aid – managed by Norton Rose Fulbright on behalf of the Australian Government