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 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 Bus...