Tax Senior Manager - Transfer Pricing

bp•Chicago, IL

1d•$180,000 - $225,000•Hybrid

About The Position

The Tax Senior Manager - Transfer Pricing (TP) is the Senior Advisor on United States (“US”) TP matters, including tax treaty provisions and the US implications of TP policies established by the OECD, UN and other international bodies. The role holder will work with other global members of the TP Team, senior members of Group Tax and their teams, our various US businesses, and bp’s Finance organisation. You will provide technical input to these groups to help shape the strategic direction of initiatives, ensuring safe and compliant operations, and supporting appropriate audit defence for the TP positions and strategies being implemented. This role will also support tax planning, tax compliance, and tax audits and appeals as they relate to BP’s Upstream, Downstream and Supply, Trading & Shipping activities, as well as centralised functional support teams (e.g. Technology, Procurement). The focus is primarily on the US, with scope also encompassing other jurisdictions. This role supports bp’s cross-border, intergroup transactions, and associated US compliance and audit defense activities. Given the materiality of cross border activities undertaken by bpUS companies, along with the need to ensure ongoing, safe compliant TP operations along with appropriate TP audit defense the economic dimensions of this role are materially well within the tens of billions of dollars per year. This is a fantastic opportunity to bring your transfer pricing expertise to life in a real-world, practical and commercial environment!

Requirements

Significant transfer pricing advisory experience.
Relevant qualifications in tax, accounting, economics, law or a related financial subject area (or equivalent experience).
Strong technical expertise in US transfer pricing laws and regulations, including a working knowledge of OECD guidelines, alongside a solid understanding of Federal income tax as applied to transactions, legal entity structures and international operations.
Experience in US corporate, partnership or international taxation is a strong advantage.
Strong financial capability, including modelling expertise and excellent analytical skills.
Ability to work effectively across multi-cultural environments, with a strong commitment to safe, compliant and reliable operations, and to fostering a culture of mutual trust, respect, and inclusion aligned with bp’s Values & Behaviours.
Strong written and verbal communication skills, with the ability to represent bp effectively with governmental agencies.
Ability to work independently and manage cross-border projects.
Proficiency in the use of digital and analytical tools, including AI-enabled solutions, Power BI, and the Microsoft Office suite.

Responsibilities

Work with personnel, transactions and data where US tax requirements are not the primary consideration, often across complex operations and deals spanning multiple businesses and functions over extended timelines.
Interpret incomplete or imperfect data, anticipating impacts that are not always readily apparent, and providing expert recommendations to solve complex problems.
Deliver timely advice and decisions—often within short timeframes and with potentially significant impact.
Coordinate and collaborate with diverse teams across multiple jurisdictions, frequently without face-to-face interaction.
Coach and support colleagues globally, aligning input from multiple locations, and ensuring shared understanding of US tax requirements where changes to processes may be required.
Support and lead transfer pricing initiatives, audits, compliance, and planning activities across the US, Canada and Latin America.
Analyze proposed legislation and regulations, advising Tax Management and business-facing tax planners on potential impacts, and ensuring compliance with evolving requirements.
Manage risk and drive efficient, standardised and simplified operations, while identifying continuous improvement opportunities and reducing complexity.
Develop subject matter expertise in BP’s related party arrangements and ensuring tax requirements are clearly understood and met.
Lead technical transfer pricing activities, including drafting and reviewing tax-related contractual language, maintaining and supporting Advanced Pricing Agreements (APAs), contributing to future APA and Competent Authority processes, and supporting ongoing business proposals, transactions and initiatives.
Lead US transfer pricing audit activities, including audit strategy, technical positions, IDR management and direct engagement with IRS examination teams, as well as approving settlements within delegated authority and conducting transfer pricing risk assessments across the bp Group.
Ensure accurate and complete reporting of cross-border intergroup transactions in the US consolidated federal income tax return, working closely with the US Tax Operations Team and continuously improving processes for data gathering, verification and disclosure.
Lead the management of external US transfer pricing advisors and the delivery of high-quality, audit-ready transfer pricing documentation.
Collaborate with the global Transfer Pricing Team to develop, implement and sustain optimised transfer pricing strategies, and ensuring compliance with applicable US rules, regulations, IRS guidance and case law.