Senior Manager, Transfer Pricing

OpenAI•San Francisco, CA

2d•Hybrid

About The Position

This role will support transfer pricing initiatives and other strategic transactions by advising on risks. In parallel, the role will serve as a core tax advisor to the business on transfer pricing matters, including business expansion, operating model, transfer pricing considerations and the tax aspects of commercial and intercompany arrangements. The Tax Director will partner closely with Legal, Finance, Corporate Development, and commercial teams to ensure tax positions are technically sound, operationally executable, and aligned with business and compliance requirements.

Requirements

12+ years of transfer pricing experience with significant responsibilities and broad experience across all aspects of transfer pricing.
Degree in Economics, Finance, Tax, or related field; CPA, JD, or Master’s in Tax preferred.
Deep expertise in OECD transfer pricing guidelines and international tax regulations.
Strong quantitative and economic analysis skills.
Experience managing transfer pricing compliance in multiple jurisdictions.
Experience in managing and designing operational transfer pricing processes.
Cross-functional project management skills and ability to influence senior stakeholders.
Excellent written and verbal communication skills for technical documentation and presentations.

Responsibilities

Lead the design, development, and implementation of comprehensive global transfer pricing strategies and policies.
Oversee preparation of transfer pricing documentation and compliance, including master files, local files, and country-by-country reports, across multiple jurisdictions and coordinate with local tax teams.
Draft and manage intercompany agreements.
Support transfer pricing aspects of business initiatives.
Evaluate APAs and oversee transfer pricing-related audits.
Build and maintain transfer pricing models and economic analyses.
Manage relationships with external transfer pricing advisors and coordinate multi-jurisdictional projects.
Monitor global transfer pricing developments, OECD guidelines, and local country changes.
Collaborate with Finance, Legal, and Business Development teams on intercompany pricing strategies.
Drive automation and efficiency improvements in transfer pricing processes and documentation.