Senior Manager, Transfer Pricing

About the Team

OpenAI Finance is responsible for ensuring the organization is set up for success in pursuit of its mission.

The Tax team is a vital part of OpenAI, ensuring compliance with tax laws and regulations while optimizing the company's tax position. We work closely with various departments to provide tax insights and strategies that support the company's growth and financial objectives.

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 Transfer Pricing Senior Manager 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 AI research and deployment company dedicated to ensuring that general-purpose artificial intelligence benefits all of humanity. We push the boundaries of the capabilities of AI systems and seek to safely deploy them to the world through our products. AI is an extremely powerful tool that must be created with safety and human needs at its core, and to achieve our mission, we must encompass and value the many different perspectives, voices, and experiences that form the full spectrum of humanity.

We are an equal opportunity employer, and we do not discriminate on the basis of race, religion, color, national origin, sex, sexual orientation, age, veteran status, disability, genetic information, or other applicable legally protected characteristic.

For additional information, please see OpenAI’s Affirmative Action and Equal Employment Opportunity Policy Statement.

Background checks for applicants will be administered in accordance with applicable law, and qualified applicants with arrest or conviction records will be considered for employment consistent with those laws, including the San Francisco Fair Chance Ordinance, the Los Angeles County Fair Chance Ordinance for Employers, and the California Fair Chance Act, for US-based candidates. For unincorporated Los Angeles County workers: we reasonably believe that criminal history may have a direct, adverse and negative relationship with the following job duties, potentially resulting in the withdrawal of a conditional offer of employment: protect computer hardware entrusted to you from theft, loss or damage; return all computer hardware in your possession (including the data contained therein) upon termination of employment or end of assignment; and maintain the confidentiality of proprietary, confidential, and non-public information. In addition, job duties require access to secure and protected information technology systems and related data security obligations.

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