Entity:
Finance

Job Family Group:
Tax Group

Job Description:

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!

Key accountabilities and challenges

You will 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. This includes interpreting incomplete or imperfect data, anticipating impacts that are not always readily apparent, and providing expert recommendations to solve complex problems.

Operating in a fast-paced and evolving area of taxation and reporting, this role requires strong technical expertise, a sound understanding of business operations, and the ability to deliver timely advice and decisions-often within short timeframes and with potentially significant impact.

Coordination and collaboration with diverse teams across multiple jurisdictions will be key, frequently without face-to-face interaction. This includes coaching and supporting colleagues globally, aligning input from multiple locations, and ensuring shared understanding of US tax requirements where changes to processes may be required.

The role includes supporting and leading transfer pricing initiatives, audits, compliance, and planning activities across the US, Canada and Latin America. This includes analysing proposed legislation and regulations, advising Tax Management and business-facing tax planners on potential impacts, and ensuring compliance with evolving requirements.

You will manage risk and drive efficient, standardised and simplified operations, while identifying continuous improvement opportunities and reducing complexity. This includes developing subject matter expertise in BP's related party arrangements and ensuring tax requirements are clearly understood and met.

Leadership and support of technical transfer pricing activities are required, 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.

You will 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.

Ensuring accurate and complete reporting of cross-border intergroup transactions in the US consolidated federal income tax return is a key accountability, working closely with the US Tax Operations Team and continuously improving processes for data gathering, verification and disclosure.

The role also includes leading the management of external US transfer pricing advisors and the delivery of high-quality, audit-ready transfer pricing documentation, while collaborating 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.

What you will bring...

• 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.

Apply now!

How much do we pay (Base)? $180k - $225k (Minimum & Maximum)

*Note that the pay range listed for this position is a genuinely expected and reasonable estimate of the range of possible base compensation at the time of posting.

This position is eligible for US Benefits - Core. This position offers paid vacation depending on your years of relevant industry experience and will range from 120 - 240 hours of vacation per year for full time employees (60 - 240 hours of vacation per year for part time employees). You will also be eligible for 9 paid holidays per year and 2 personal choice holidays. You may learn more about how we calculate paid vacation and view our generous vacation and holiday schedules at Core U.S. Benefits . Bp has a parental leave policy as well, which offers up to 8 weeks' paid leave for the birth or adoption of a child. Learn more by visiting Core U.S. Benefits.

We offer a reward package to enable your work to fit with your life. These offerings include a discretionary annual bonus program, long-term incentive program, and generous retirement benefits that include a 401k matching program. These benefits include a pension for eligible employee. You may learn more about our generous benefits at Core U.S. Benefits.

As part of bp's wellbeing package, bp offers access to health, vision, and dental insurance, as well as life and Short-Term Disability and Long-Term Disability. You may learn more about our generous benefits at Core U.S. Benefits.

Travel Requirement
Up to 10% travel should be expected with this role

Relocation Assistance:
This role is not eligible for relocation

Remote Type:
This position is a hybrid of office/remote working

Skills:
acquisitions and disposals activity, Analytical Thinking, Commercial Acumen, Creativity and Innovation, Data Management, Digital Fluency, Direct and indirect tax compliance and accounting, Economic modelling, Financial Reporting, Influencing tax law and policy, Interpreting and applying tax law, Management of change, Managing tax dispute resolution and controversies, Project Management, Risk Management, Stakeholder Engagement, Tax advice for mergers, Tax advisory, Tax compliance process management, Tax reporting and control, Transfer Pricing