Senior Manager - US Transfer Pricing

Coupang•Seattle, WA

1d•$155,000 - $267,000

About The Position

Coupang is seeking a Senior Manager of Transfer Pricing to lead US-based transfer pricing operations and transactional planning as the company expands into new global markets and business lines. The role is highly cross-functional and involves identifying risks and opportunities, operationalizing transfer pricing changes, and partnering with business leaders to translate complex operating models into defensible tax positions. Approximately 20% of the role supports broader international tax planning and compliance beyond transfer pricing. The position leads operational transfer pricing for intercompany transactions, including recurring calculations, true-ups, journal-entry inputs, and period-end close schedules, and embeds policies into high-volume, systems-driven commerce environments. It partners with business operations and global transfer pricing colleagues to scale consistent, audit-ready frameworks, and leads process studies to improve adjustment workflows and mitigate customs revaluation and Permanent Establishment risks. The role develops transfer pricing strategies for tangible asset transfers, intercompany services, royalties, and intellectual property, including DEMPE analyses and support for intercompany financing. It also supports tax authority audits, APA and MAP matters, and oversees external advisers on global documentation, benchmarking, and compliance projects. Broader international tax responsibilities include planning, restructuring, compliance, and support for quarterly and annual close and financial reporting, including ASC 740 and FIN 48 analyses and transfer pricing reserves.

Requirements

Bachelor’s degree in Accounting, Economics, Finance, or a related field.
12+ years of transfer pricing experience in a Big 4 public accounting firm, law firm, or large multinational technology company.
Deep technical expertise and applied knowledge of US transfer pricing regulations (IRC Section 482) and OECD Transfer Pricing Guidelines, with the ability to translate them into practical, business-aligned solutions.
Operational and transactional planning transfer pricing experience, including maintaining and updating calculation models and intercompany agreements.
Experience structuring complex intercompany transactions, assessing transfer pricing risk, and integrating acquired companies or intangibles into global supply chains.
Hands-on experience supporting APA matters and defending transfer pricing positions during tax authority audits.
Ability to translate complex, evolving global tax disclosure requirements into compliant operational reporting frameworks.
Advanced financial modeling skills and proficiency managing large datasets.

Nice To Haves

Master’s degree, CPA, or JD.
In-house experience at a large US multinational enterprise in the technology sector.
Curiosity and willingness to investigate evolving business models, ask critical questions, and understand the rationale behind data.
Self-motivation, comfort with ambiguity, autonomy, end-to-end project ownership, and ability to thrive without direct supervision in an entrepreneurial environment.
Exceptional stakeholder management and communication skills, including the ability to explain complex tax concepts as actionable advice for non-tax leaders in Finance, Legal, and Operations.
Track record of process improvement and using technology and automation to streamline workflows, scale operations, and reduce manual inefficiencies.
Adaptability and resilience in a fast-paced, high-growth environment, with the ability to pivot as the company enters markets or launches business lines.
Leadership skills, including mentoring and coaching team members, guiding cross-functional stakeholders without formal authority, and advising executive leadership.

Responsibilities

Lead transactional planning initiatives and implement operational transfer pricing for intercompany transactions.
Translate transfer pricing policies into recurring intercompany calculations, true-ups, journal-entry inputs, and period-end close schedules.
Embed transfer pricing policies into high-volume, systems-driven commerce environments.
Partner with business operations and global transfer pricing teams to scale frameworks across businesses and markets while ensuring audit readiness and systemic consistency.
Lead operational studies to optimize adjustment processes and eliminate resource bottlenecks; mitigate customs revaluation and Permanent Establishment risks.
Lead transfer pricing strategies for tangible asset transfers, intercompany services, and royalty models.
Advise on global intangible alignment and perform DEMPE analyses to support cross-border tax strategies and IP integrations.
Assist with implementing financial transactions, including debt capacity analyses for intercompany financing arrangements.
Support and represent Coupang in tax authority audits, APA matters, and MAP matters by preparing technical analyses, economic exposure assessments, and negotiation support.
Serve as the primary liaison to external advisers and Big 4 partners.
Direct external advisers on global documentation projects, comparable company searches, benchmarking studies, and preparation of Master Files and Local Files.
Monitor OECD requirements, BEPS, Pillar Two, and Country-by-Country Reporting to strengthen global compliance and risk management.
Support international tax planning, restructuring, and compliance deliverables outside standard transfer pricing scope.
Support quarterly and annual close and financial reporting workflows, including ASC 740 and FIN 48 analyses, provision memoranda, and transfer pricing reserve calculations.