Principal Lead, Transfer Pricing

Chick-fil-A, Inc. • Atlanta, GA

8d • Hybrid

About The Position

The Professional/Individual Contributor Staff member is responsible for performing work responsibilities, building relationships, and sharing expertise and experience as he/she contributes to specific bodies of work, builds connections, and optimizes performance. The Chick-fil-A Tax Department is responsible for tax compliance, technology, special projects, research and audit defense functions for independently-owned franchised restaurants and corporate activities. We exist to provide tax planning, regulatory reporting and consulting to stakeholders, governments, external auditors and business leaders. As we grow in complexity and global footprint, we seek to influence business decisions, reduce tax liability and mitigate risk. This role is responsible for developing and maintaining Chick-fil-A’s global transfer pricing strategy, ensuring intercompany transactions are aligned with business operations and international tax requirements. The position serves as the company’s subject matter expert on transfer pricing, providing technical leadership, advising on complex cross-border matters, and establishing defensible positions across jurisdictions. The role also partners with business, Finance, Legal, and external advisors to manage risk, support strategic growth, and maintain globally consistent and audit-ready transfer pricing policies.

Requirements

• Expert knowledge of US and International Transfer Pricing Principles, including OECD Guidelines and arm’s length standards in cross-border intercompany transactions
• Strong understanding of International Tax concepts, Legal entity structures, intercompany agreements, and global tax controversy considerations
• Advaned technical research and analytical skills
• Strong business partnering and communication skills with ability to translate technical concepts into pracftical recommendations for senior leaders
• Ability to independently lead highly complex Transfer Pricing matters with minimal oversight and exercise sound judgment in areas where guidance is ambiguous
• Ability to proactively identify risks, assess the impact of business changes, and develop sustainable solutions

Responsibilities

• Own and evolve Chick-fil-A’s global transfer pricing strategy, proactively adapting intercompany pricing models in response to business expansion, changing operating models, and evolving global tax regulations
• Evaluate and determine the arm’s length nature of intercompany transactions (e.g., royalties, management fees, and other cross-border arrangements), forming defensible positions that align financial outcomes with operational substance across multiple jurisdictions
• Lead technical analysis and decision-making for transfer pricing matters, including interpreting OECD guidance and local country rules, assessing how changes impact existing policies, and determining appropriate positions where guidance is ambiguous or evolving
• Partner with Legal to structure and review intercompany agreements, ensuring contractual terms accurately reflect pricing policies and underlying business arrangements, and are aligned with global transfer pricing strategy and audit defensibility requirements
• Collaborate with Finance, Tax, and business stakeholders to evaluate intercompany transactions, recommend allocation methodologies, and ensure consistent and supportable reporting across jurisdictions
• Drive proactive risk identification and audit readiness, including developing robust supporting documentation, anticipating areas of challenge, and ensuring positions are consistent and defensible across multiple country tax authorities
• Advise senior leadership on transfer pricing implications of business decisions, including expansion into new markets, entity structuring, and changes in operating models, balancing tax efficiency, risk, and operational practicality
• Manage and direct external advisors and benchmarking studies, critically evaluating conclusions and ensuring outputs are aligned with Chick-fil-A’s facts, strategy, and risk tolerance—not simply accepted at face value

What This Job Offers

• Job Type: Full-time
• Career Level: Principal