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OpenAI

Senior Manager, Transfer Pricing

OpenAI

. Lead the design, development, and implementation of comprehensive global transfer pricing strategies and policies.

Posted 5/7/2026full-timeSan Francisco • California • 🇺🇸 United StatesSenior💰 $297,000 - $330,000 per yearWebsite

About the role

Key responsibilities & impact
  • 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.

Requirements

What you’ll need
  • 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.

Benefits

Comp & perks
  • Medical, dental, and vision insurance for you and your family, with employer contributions to Health Savings Accounts
  • Pre-tax accounts for Health FSA, Dependent Care FSA, and commuter expenses (parking and transit)
  • 401(k) retirement plan with employer match
  • Paid parental leave (up to 24 weeks for birth parents and 20 weeks for non-birthing parents), plus paid medical and caregiver leave (up to 8 weeks)
  • Paid time off: flexible PTO for exempt employees and up to 15 days annually for non-exempt employees
  • 13+ paid company holidays, and multiple paid coordinated company office closures throughout the year for focus and recharge, plus paid sick or safe time (1 hour per 30 hours worked, or more, as required by applicable state or local law)
  • Mental health and wellness support
  • Employer-paid basic life and disability coverage
  • Annual learning and development stipend to fuel your professional growth
  • Daily meals in our offices, and meal delivery credits as eligible
  • Relocation support for eligible employees
  • Additional taxable fringe benefits, such as charitable donation matching and wellness stipends, may also be provided.

ATS Keywords

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Applicant Tracking System Keywords

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Hard Skills & Tools
transfer pricingeconomic analysiscompliance documentationintercompany agreementstransfer pricing modelsAPAs evaluationaudit managementoperational transfer pricing processesquantitative analysismulti-jurisdictional compliance
Soft Skills
cross-functional project managementinfluencing senior stakeholderswritten communicationverbal communicationcollaborationrelationship managementstrategic thinkingproblem-solvingleadershipautomation improvement
Certifications
CPAJDMaster’s in Tax