Job Description

We are seeking an experienced Senior Manager / Director to join our Transfer Pricing (“TP”) team, with a focus on TP advisory and controversy matters. This role will work closely with our Tax Partners across Vietnam and other jurisdictions.

The successful candidate will advise clients on the tax and TP implications of business model design, operating model transformation, supply chain restructuring, and cross-border value creation, along with local TP compliance services. Beyond technical excellence, this individual is expected to build trusted client relationships, lead multi-disciplinary teams, develop market propositions, and contribute to the growth of the practice.

This role is well suited for a commercially minded tax and TP professional who combines strong technical capability with leadership, client relationship management, and business development experience.

Key Accountabilities:

• Lead complex client engagements involving TP advisory, local documentation compliance, value chain alignment, business model optimisation, and operating model transformation.

• Advise multinational and local clients on business restructurings, operating model changes, service model design, and other TP-related matters.

• Analyse functions, assets, risks, and profit allocation across multinational groups to assess alignment between commercial substance and value creation.

• Provide strategic guidance on substance alignment, DEMPE considerations, intangible ownership and development structures, and regional operating models.

• Develop and maintain strong client relationships, acting as a trusted advisor on strategic TP matters.

• Lead multi-disciplinary teams, coach and mentor team members, and ensure delivery of high-quality client solutions.

• Identify and pursue new business opportunities, support proposal development, and contribute to thought leadership initiatives.

• Collaborate with Partners and international teams to deliver integrated solutions for multinational clients.

Job Qualification & Experience:

• Bachelor's degree in Accounting, Law, Economics, Finance, Business, Tax, or a related discipline.

• For Senior Manager: typically 8–12 years of relevant TP or advisory experience.

• For Director: typically 12+ years of relevant experience, including leadership of complex client engagements and business development activities.

• CPA, CA, ACCA, or equivalent professional qualification preferred.

• Strong experience within professional services and/or multinational organisations.

• Deep understanding of OECD TP principles and practical application.

• Experience in TP advisory and planning, business restructurings, operating model transformation, value chain analysis, DEMPE analysis, and tax controversy matters.

• Demonstrated experience leading cross-border projects and multidisciplinary teams.

• Strong stakeholder management, leadership, business development, analytical, and communication skills.

• Experience working with multinational groups across APAC is strongly preferred.

Due to volume of applications, we regret only shortlisted candidates will be notified. Candidates will only be contacted by authorised Deloitte Recruiters via firm’s business contact number or business email address.