Summary
Overview
Work History
Education
Skills
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Software
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SATHIYA NANMENDER RAJAGOPAL @ Thivaan CPA (Aust.)

SATHIYA NANMENDER RAJAGOPAL @ Thivaan CPA (Aust.)

Specialist Tax Transfer Pricing
The Andes Condo Villa, Jalan Mas 3, 58200 Kuala Lumpur

Summary

Passionate and results-driven tax practitioner with over 7 years of in-depth experience in transfer pricing specialization with strong focus on in-house compliance and advisory matters. Expertise in multi-jurisdictional transfer pricing rules and principles, complemented by solid financial accounting and taxation background. Excels at managing, developing, and implementing robust global transfer pricing strategies and policies to ensure regulatory compliance. Dedicated to staying current with evolving transfer pricing legislations, including the complexities of OECD guidelines and local country-specific regulations. Proven track record of advising senior leadership on complex transfer pricing matters and controversy resolution with the ability to deliver practical solutions that optimize tax efficiencies. Skilled at collaborating with cross-functional teams and stakeholders at various levels to effectively drive strategic business decisions and mitigate risks.

Overview

16
16
years of professional experience
1
1
Certification
3
3
Languages

Work History

Specialist Tax Transfer Pricing

BHP Shared Services Malaysia Sdn Bhd
07.2018 - Current
  • Primary support to the Head of Transfer Pricing with responsibilities over the management of global Transfer Pricing compliance and advisory activities across the group.
  • Apply understanding of tax laws, accounting concepts, technological tools and relevant transfer pricing guidance to scope, plan and execute core group level transfer pricing compliance and advisory projects through-out the year.
  • Initiate and plan TP advisory work for newly identified intra-group transactions by interpreting and applying the relevant TP principles and guidelines to determine appropriate treatment and prepare policy documents to mitigate audit risk and defend TP position.
  • Responsible to manage, review and update the group level global transfer pricing matrix with the latest available information where it serves as the single source of reference for all group tax members to monitor yearly transfer pricing deliverables and activities.
  • Monitor the progression of key consultation matters and new changes to the transfer pricing legislation and guidance across the world to assess the relevant impact to the group and keep internal stakeholders informed of the new requirements.
  • Preparation of governance material such as sign-off memos and briefing papers for the public officers prior to the lodgement/submission of statutory local country-specific transfer pricing disclosures.
  • Provide strategic guidance and ad-hoc reporting in relation to existing and upcoming transfer pricing controversies as and when requested by senior finance and tax leadership members.
  • Work closely with cross-functional teams to implement necessary improvement projects and automation to optimize efficiency and accuracy of routine transfer pricing operations and policies across the group for all relevant jurisdictions.
  • Attend, escalate & prepare strategic responses for all transfer pricing related Request for Information (RFI), Pre-lodgement Compliance Review (PCR) and other audit request from tax authorities from different jurisdictions.
  • Responsible for the preparation of Transfer Pricing documentation (local files) including the functional and economic analysis, review benchmark studies and comparability analysis to ensure compliance with OECD BEPS Action 13 framework and country-specific regulations.
  • Reconcile the group’s transfer pricing methods and help to support the on-going maintenance and implementation of group’s head office recharge mechanism and other intra-group transactions.
  • Review and update intercompany agreements and framework documentation for all major intra-group transactions such as the service charges, guarantees, financing, derivatives, commodity sales, intangible and etc which sets-out the terms and conditions governing the transactions as well as to support the arm’s length position.
  • End-to-end preparation of Country-by-Country Reporting (CBCR - Table 1 to 3) ensuring accurate consolidation of financial data, entity information and explanatory notes to ensure proper interpretation and compliance of OECD BEPS Action 13 and local regulatory requirement.
  • Manage timely submission of CbC Notifications for various countries in compliance with OECD requirements ensuring accurate identification of reporting entities and jurisdictions.
  • Responsible for the end-to-end preparation and lodgement of Australian Local File (Part A & B) including data collection, transactional analysis and alignment with transfer pricing methods in accordance to ATO requirement.
  • Manage the Annual Compliance Report (ACR) for the existing Bilateral Advance Pricing Agreement (BAPA), including the validation of intra-group service charge (IGSC) transactions against the agreed TP methods and other terms to ensure compliance and timely submission in accordance with ATO and foreign tax authority guidelines.
  • Prepare internal transfer pricing adjustment proposal by analyzing a range of various intercompany transactions against the arm's length benchmarks and recommend year-end adjustment to adhere with existing transfer pricing policies.
  • Prepare and maintain OECD-compliant Master File providing high-level overview of BHP Group's structure, global operations, transfer pricing policies, intangibles, financing activities and etc in line with BEPS Action 13 requirement.
  • Responsible to review and validate Related Party Transaction (RPT) disclosures required for local country-specific tax return to ensure reflection of intra-group transactions are consistent with transfer pricing documentation.
  • Manage and provide day-to-day leadership for a team of two TP analysts, overseeing workload allocation, reviewing deliverables and supporting their professional development and technical growth.

Specialist Tax Operations

BHP Shared Services Malaysia Sdn Bhd
11.2017 - 07.2018
  • Preparation of monthly, half-yearly and annual tax account reconciliations, tax returns, deferred tax balance proofs and tax provisions primarily for APAC corporate entities.
  • Preparation of tax proofs and reconciliations in line with the allocated frequency to ensure accurate tax balances are reported.
  • Review of tax sensitive accounts including liaising with management and financial accountants and the wider business where necessary to resolve queries.
  • Participate in risk assessment activities for income tax, SOX and other compliance related maters to ensure compliance.
  • Build relationships with other departments to ensure proactive engagement of the tax team for assistance with tax technical matters, including provision of tax training, analysis and technical guidance to relevant areas of the business.
  • Provide support in the preparation of tax accounting position papers for major transactions.
  • Assist in the development, implementation and review of tax policies and procedures across all taxes and ensure compliance.
  • Assist with requests from Tax Reporting, Transfer Pricing and external auditors in connection with taxation and financial accounting audits.

Senior Accountant

International SuperConcepts Sdn Bhd
06.2014 - 10.2017
  • Manage end-to-end statutory annual financial reporting including lodgement of tax returns for a portfolio of 100+ Australian self-managed superannuation accounts (SMSF).
  • Preparation of full set EOY financial report package including trial balances, profit & loss statement, balance sheet, member balance statements, tax return forms etc including documentation for statutory audits.
  • Prepare and lodge Business Activity Statement (BAS) to ensure timely tax instalment activities such as GST & PAYG are completed.
  • Processing of Actuarial Certificate before finalization of accounts to ensure appropriate exempt incomes & deductible non-deductible expenses are reflected in client's tax return forms.
  • Identification and rectification of compliance breaches on client accounts including interpretation of Auditors Convention Reports (ACRs) to the clients.
  • Manage tax audits to act as an intermediary between client and tax authorities to resolve complex controversies.
  • Supervise and manage daily operational routine for a team of 6-7 accountants, analyst & admins including review and sign-off on completed tasks to ensure adherence to statutory regulations, accounting standards and other legal requirements.
  • Provide technical support to assist the team with difficult and complex accounting & taxation issues, interpretation of financial statements and legislation issues.
  • Identify knowledge & skill gaps within the team, conduct necessary training, and develop quality monitoring tools to promote best practices.
  • Conduct periodic evaluations of various SLAs in place to align service delivery and manage client's expectation.
  • Investigate validity of client complaints/issues and ensure timely execution of amendments & resolutions are carried out including tax planning requests.
  • Participate in weekly planning and status meetings with leadership team to escalate & address productivity variances, spare capacities, and quality issues.

Senior Fund Accountant

RBC Investor & Treasury Services Sdn Bhd
03.2012 - 06.2014
  • Facilitate daily NAV operation routine alongside the manager for a team of ten junior accountants.
  • Perform daily quality reviews, sign-off and validate final NAV prepared by junior team members.
  • Facilitate coordination among internal teams and external service providers to ensure client deliverables are met and quality issues mitigated on timely manner.
  • Track SLA breaching SLA instances and escalate to management for resolution.
  • Engaged in regular stakeholder meetings involving custodians, brokers and auditors to ensure resolution of outstanding operational issues.
  • Execute regular fund fact sheet and SLAs reviews to ensure accuracy and confirm compliance with fund specifics & allocation guidelines.
  • Facilitate training sessions and on-boarding for new joiners.

Fund Accountant

RBC Investor & Treasury Services Sdn Bhd
01.2011 - 03.2012
  • Support the daily, monthly & yearly accounting & reporting functions for European domiciled hedge funds, mutual funds, pooled funds and segregated funds.
  • Responsible for daily calculation of NAVs (Net Asset Value) for assigned funds including booking of journal entries and maintain general ledgers and trial balance for assigned funds.
  • Perform monthly, quarterly & yearly closing and prepare financial reports including investor statement for funds under assignment.
  • Ensure reconciliation of unit holder capital stock, cash and asset holdings are duly performed on a timely manner.
  • Adhere to documented accounting & reporting procedures and relevant controls while seeking improvement opportunities.

Stock Controller

OE Design Sdn Bhd
06.2009 - 12.2010
  • Function as support to the cost accountant & finance manager.
  • Assist with plant-level cost & controls activities including management accounting, cost accounting, work-order audits, inventory reconciliations, and cost analysis.
  • Ensure continuous review & improvement on inventory control procedures.
  • Analyze actual labour, material, and overhead costs against standard costing budget.
  • Prepare analysis of fixed spending by departments and broadcast actual vs budget, identify and escalate variances to finance manager.
  • Assist cost accountant in preparation of monthly financial reports related to all costing & inventory matters.
  • Conduct physical stock count of raw materials & WIP items with production supervisors on monthly basis.
  • Conduct monthly, quarterly and yearly stock audits at all showrooms nationwide for finished goods.

Education

Post-Graduate Certificate -

Certified Practising Accountants (CPA)
Australia
04.2001 -

Bachelor's Degree - Commerce

Murdoch University
Perth, Western Australia
02-2009

Certificate IV (University Foundation Studies) -

Curtin International College
Perth, Western Australia
08-2005

Malaysian Certificate of Education (SPM) -

St.Marks Secondary School
Butterworth, Penang, Malaysia
04.2001 -

Skills

Accomplishments

  • Within 2 years of joining the team successfully completed a series of global transfer pricing documentation project at BHP for over 5 different APAC countries covering 20+ entities ensuring compliance to BEPS Action 13 requirements, which reduced the reliance on external consultants with a relevant annual cost savings of approximately $200k AUD.


  • Designed and rolled out a centralized transfer pricing matrix document covering all relevant jurisdictions where BHP Group Ltd operates, it serves as a guiding document for the group tax function, improving audit readiness and standardizing TP operations across the group and resulted in zero TP adjustments and TP related penalties for 5 consecutive years since implementation.


  • Resolved multiple controversies around the contribution and pension issues for high-net worth clients at SuperConcepts ensuring compliance caps are met to minimize risk of tax penalties which eventually maintained the overall client retention rate at 99% over a consecutive period of 2 years.


  • Trained and onboarded more than 10 junior fund accountants at RBC within a span of 1 year which resulted in a cost-saving of approximately 40% from what was previously spent on external training costs.


  • Spearheaded a process improvement project at RBC to transition a complex derivative analysis & valuation task into a single-specialized functional team which improved overall NAV calculation efficiency and reduction of derivative related NAV errors by 30% within 6 months and was declared BAU.

Software

Microsoft 365 (Words, Excel, PowerPoint etc)

SAP S/4HANA (ERP)

SAP Analysis for Office - AFO (Data Analysis)

SharePoint (Content Management)

Oracle JD Edwards EnterpriseOne (ERP)

Diligent Entities (Entity Management)

SAP Business Objects Business Intelligence - BOBJ (Data Reporting)

Workware Real-Time (Productivity Data Analysis)

Power BI / Power Query

Certification

CPA Australia

Other information

  • Date of Birth: 23rd August 1985


  • Nationality: Malaysian


  • Marital Status: Married


  • Current Salary: RM11,070.00


  • Availability: 2 months' notice


  • Willingness to travel: Yes


  • Willingness to relocate: Considerable

Interests

Travelling

Cycling

Reading

Fishkeeping

References

  • Name: Hezza Hanif
  • Position: Senior Manager – Regional Tax
  • Company: SEEK Malaysia, Kuala Lumpur
  • Contact: (M) +6012 614 1605 (E) Hezza.hanif@gmail.com
  • Relationship: Ex - Reporting Manager at BHP
  • Years known: Nov 2017 to present


  • Name: Lim Fang Jin
  • Position: Lead Tax Operations
  • Company: BHP Shared Services Malaysia Sdn Bhd, Kuala Lumpur
  • Contact: (M) +6012 923 7832 (E) fangjin.lim@bhp.com
  • Relationship: Tax colleague at BHP
  • Years known: Nov 2017 to present

Work Availability

monday
tuesday
wednesday
thursday
friday
saturday
sunday
morning
afternoon
evening
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Timeline

Specialist Tax Transfer Pricing

BHP Shared Services Malaysia Sdn Bhd
07.2018 - Current

Specialist Tax Operations

BHP Shared Services Malaysia Sdn Bhd
11.2017 - 07.2018

Senior Accountant

International SuperConcepts Sdn Bhd
06.2014 - 10.2017

Senior Fund Accountant

RBC Investor & Treasury Services Sdn Bhd
03.2012 - 06.2014

Fund Accountant

RBC Investor & Treasury Services Sdn Bhd
01.2011 - 03.2012

Stock Controller

OE Design Sdn Bhd
06.2009 - 12.2010

Post-Graduate Certificate -

Certified Practising Accountants (CPA)
04.2001 -

Malaysian Certificate of Education (SPM) -

St.Marks Secondary School
04.2001 -

Bachelor's Degree - Commerce

Murdoch University

Certificate IV (University Foundation Studies) -

Curtin International College

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SATHIYA NANMENDER RAJAGOPAL @ Thivaan CPA (Aust.)Specialist Tax Transfer Pricing