Senior Manager, Transfer Pricing

About the Role

The Tax team at Openai is responsible for advising on risks related to transfer pricing initiatives and strategic transactions. It also serves as a core tax advisor to the business on transfer pricing matters, including business expansion, operating model considerations, and the tax aspects of commercial and intercompany arrangements. The team partners 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.

What You Will Do

• Lead the design, development, and implementation of comprehensive global transfer pricing strategies and policies.
• Oversee the preparation of transfer pricing documentation and compliance, including master files, local files, and country-by-country reports, across multiple jurisdictions.
• Coordinate with local tax teams to ensure compliance with local tax regulations.
• Draft and manage intercompany agreements.
• Support transfer pricing aspects of business initiatives, such as mergers and acquisitions.
• Evaluate Advance Pricing Agreements (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.

What We Are Looking For

• 12+ years of transfer pricing experience with significant responsibilities and broad experience across all aspects of transfer pricing.
• Degree in Economics, Finance, Tax, or a 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.

Nice to Have

• Experience with tax technology and automation tools.
• Knowledge of data analytics and visualization tools.
• Certification in a related field, such as a CPA or CMA.
• Experience working in a fast-paced, dynamic environment.

Benefits and Perks

• Competitive salary and benefits package.
• Opportunity to work with a leading AI research and deployment company.
• Collaborative and dynamic work environment.
• Flexible work arrangements, including remote work options.
• Professional development and growth opportunities.
• Access to cutting-edge technology and tools.
• Comprehensive health and wellness programs.
• Generous paid time off and holiday schedule.

• Tip: Highlight your experience with transfer pricing software and tools, such as Thomson Reuters or Bloomberg, to stand out as a candidate.
• Ensure your resume and cover letter are tailored to the specific requirements of the role, emphasizing your expertise in OECD guidelines and international tax regulations.
• Be prepared to discuss your approach to managing transfer pricing compliance in multiple jurisdictions and how you stay up-to-date with global developments.
• Develop a portfolio or examples of your work in transfer pricing, including any successful audits or APA negotiations.
• Research Openai's mission and values, and be ready to explain how your skills and experience align with the company's goals.
• When negotiating salary, consider the total compensation package, including benefits and perks, and be prepared to discuss your expectations based on industry standards.