OpenAI· Finance· San Francisco
Senior Manager, Transfer Pricing
Comp$297K – $330K
Classified Tasks (16)
Automate 0%Augment 44%Human-Only 56%
Augment (7)
AI assists, human decides
Oversee preparation of transfer pricing documentation and compliance, including master files, local files, and country-by-country reports across multiple jurisdictions.
operational
Draft and manage intercompany agreements.
technical
Support transfer pricing aspects of business initiatives and strategic transactions.
analytical
Oversee transfer pricing-related audits.
operational
Build and maintain transfer pricing models and perform economic analyses.
analytical
Monitor global transfer pricing developments, OECD guidelines, and local country regulatory changes.
analytical
Drive automation and efficiency improvements in transfer pricing processes and documentation.
operational
Human-Only (9)
Requires human judgment
Lead the design, development, and implementation of comprehensive global transfer pricing strategies and policies.
leadership
Coordinate with local tax teams on transfer pricing documentation and compliance matters.
communication
Advise on transfer pricing risks for strategic transactions and other business initiatives.
analytical
Evaluate advance pricing agreements (APAs).
technical
Manage relationships with external transfer pricing advisors and coordinate multi-jurisdictional projects.
leadership
Collaborate with Finance, Legal, Corporate Development, and commercial teams on intercompany pricing strategies and tax positions.
communication
Ensure tax positions are technically sound, operationally executable, and aligned with business and compliance requirements.
technical
Advise the business on transfer pricing considerations related to business expansion and operating model changes.
analytical
Advise on tax aspects of commercial and intercompany arrangements.
technical
Job description
Senior Manager, Transfer Pricing | OpenAI Careers ## Senior Manager, Transfer Pricing Finance - San Francisco Apply now(opens in a new window) **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 E