OpenAI

Senior Manager, Transfer Pricing

OpenAI$150K — $200K *
Legal & Accounting
11 - 15 years of experience
Job Overview by Ladders

Qualifications

  • 12+ years of transfer pricing experience with significant responsibilities.
  • 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 global transfer pricing strategies and policies.
  • Oversee transfer pricing documentation and compliance across jurisdictions.
  • 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.
  • Drive automation and efficiency improvements in transfer pricing processes.

Benefits

  • Hybrid work model of 3 days in the office per week.
  • Relocation assistance for new employees.
Full Job Description
About the Role:

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.

This role is based in San Francisco, CA. We use a hybrid work model of 3 days in the office per week and offer relocation assistance to new employees.

In this role, you will:
  • 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.


You might thrive in this role if you have:
  • 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.


About OpenAI

OpenAI is an artificial intelligence research laboratory consisting of the for-profit corporation OpenAI LP and its parent company, the non-profit OpenAI Inc. The company was founded in 2015 by a group of technology leaders, including Elon Musk, Sam Altman, Greg Brockman, Ilya Sutskever, and John Schulman. OpenAI's mission is to develop and promote friendly AI for the betterment of humanity. The company has developed a number of cutting-edge AI technologies, including GPT-3, a language processing system that can generate human-like text. OpenAI has received funding from a number of high-profile investors, including LinkedIn co-founder Reid Hoffman and venture capitalist Peter Thiel.
Learn more about OpenAI
Size
100 employees
Industry
Founded
2015

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