CharteredPartners is seeking an experienced transfer-pricing professional to join our client in Hong Kong at Director level. The successful candidate will lead transfer-pricing advisory and documentation delivery, support business development across the practice, and serve as a senior technical reference point on intercompany pricing, value-chain analysis and dispute defence. Specific qualifications, regulatory fluency and technical breadth are detailed in the sections that follow.

Confidential Client. Applying to this position means that you are interested to have an initial confidential discussion about how we can help you to identify and join a new accounting-firm practice. With your authorisation we will exclusively run the entire application and recruitment process for you, keeping you apprised at every step. With over 30 years' combined experience of helping the most talented accounting, audit, tax and advisory professionals to make safe, well-judged moves into rewarding new roles, we have the experience, network and ability to help you.

Key Responsibilities:

• Lead the design and delivery of transfer-pricing policies, intercompany agreements and operating-model reviews for multinational groups headquartered in or routed through Hong Kong.
• Prepare and review master files, local files and country-by-country reporting consistent with BEPS Action 13 and the Inland Revenue Department's documentation requirements.
• Advise on the interaction between transfer pricing and Hong Kong's territorial source principle and the foreign-sourced income exemption (FSIE) regime.
• Manage IRD enquiries, transfer-pricing audits and advance pricing arrangement applications, and assist clients with mutual-agreement-procedure cases under the CDTA network.
• Assess the transfer-pricing implications of Pillar Two, including the Hong Kong Minimum Top-up Tax and income-inclusion rule applicable from 2025.
• Support origination and proposals, scoping engagements and building relationships with in-house tax and finance leaders.
• Develop and supervise managers and associates, and own technical quality across documentation and benchmarking deliverables.

Required Qualifications and Skills:

• Member of the Hong Kong Institute of Certified Public Accountants (HKICPA), or an equivalent recognised accountancy or tax qualification.
• At least ten years of dedicated transfer-pricing experience, with significant time in a professional services environment.
• Detailed knowledge of the OECD Transfer Pricing Guidelines and their application under Hong Kong law.
• Fluency in the two-tiered profits tax rates of 8.25% and 16.5% and the territorial basis of taxation.
• Hands-on experience preparing BEPS Action 13 documentation and defending positions before the IRD.
• Strong economic-analysis and benchmarking capability, including comparables searches and financial modelling.
• Working understanding of Pillar Two and its impact on intercompany arrangements.
• Excellent report-writing skills and the ability to translate economic analysis into defensible positions.
• Confident client-facing and stakeholder-management abilities.
• Right to work in Hong Kong, or eligibility to secure the appropriate visa.

Preferred Experience:

• Experience across financial services, trading, technology or consumer-goods value chains.
• Familiarity with the Greater Bay Area and broader regional intercompany flows.
• Exposure to APA negotiation and competent-authority proceedings.
• Knowledge of customs and indirect-tax interactions with transfer-pricing adjustments.
• A record of contributing to thought leadership or professional-body technical committees.
• Mandarin or Cantonese language ability alongside English.

Compensation:

Competitive package commensurate with seniority and experience, including base, performance-based bonus, long-term incentives and (where applicable) partner-track participation.

Next Steps:

This opportunity is open to candidates who hold or can obtain the right to work in Hong Kong and who match the above criteria. Please apply to receive prompt contact from an experienced and specialist accounting-firm recruitment consultant.

Chartered Partners is a trading style of Feltan Associates Pte Ltd; an international Executive Search, Recruitment and Consulting business based in Singapore, licensed and regulated by the Singapore Ministry of Manpower to conduct recruitment services for clients. UEN: 202225620G. EA Licence 23S1672. All rights reserved.