Global Director – Transfer Pricing

This is a fully remote position, open to applicants in California, +18 more states.

📋 Description

• Lead the global transfer pricing strategy, governance, compliance, and controversy agenda for the company.

• Provide guidance to senior tax, finance, treasury, legal, and business leaders on arm’s-length policies for intercompany transactions.

• Own and enhance the global transfer pricing framework relating to services, intellectual property, cost-sharing arrangements, restructurings, and intercompany financing.

• Collaborate with leaders in business, finance, supply chain, R&D, legal, controllership, and treasury.

• Conduct functional analyses, benchmarking studies, intangible valuations, profit-split assessments, and financial transaction analyses.

• Oversee Master File, Local Files, country-by-country reporting, local forms, and contemporaneous documentation.

• Establish processes for forecasts, target margins, quarterly monitoring, true-ups, journal entries, management reporting, and reconciliation to tax returns and statutory accounts.

• Develop a global control framework that encompasses policy governance, intercompany agreements, data lineage, retention, risk assessment, and KPIs.

• Lead global transfer pricing controversy and audit defense initiatives.

• Manage advance pricing agreements, mutual agreement procedures, competent-authority matters, and settlement strategies.

• Collaborate on mergers, acquisitions, integrations, divestitures, legal-entity changes, value-chain transformations, and new business models.

• Stay informed on OECD, U.S., and local-country developments and evaluate their implications.

• Utilize AI-driven monitoring and data-driven scenario modeling for Pillar Two and country-by-country analytics.

• Partner with Treasury on pricing for intercompany loans, guarantees, cash pools, and other financial transactions.

• Support tax accounting by evaluating exposures, uncertain tax positions, reserves, disclosures, and management reporting.

• Cultivate relationships with regional finance and tax teams and provide stakeholder training.

• Effectively communicate complex issues to executive leadership.

• Foster innovation in financial modeling and transfer pricing risk management through AI, automation, and advanced analytics.

• Advocate for wellbeing and a supportive workplace environment.

⛳️ Requirements

• Advanced degree in economics, accounting, finance, tax, or a related field.

• JD, LLM, CPA, or an equivalent professional credential is preferred.

• A minimum of 12+ years of progressively responsible experience in transfer pricing.

• Significant leadership experience within a complex multinational enterprise, a major advisory firm, or a combination of both.

• In-depth understanding of OECD principles as well as U.S. and local-country transfer pricing regulations.

• Expertise in documentation, economic analysis, intellectual property, services, financial transactions, restructurings, and dispute resolution.

• Experience in designing and implementing global policies across various jurisdictions, legal entities, business models, and enterprise systems.

• Proven track record in leading audits and managing controversy matters.

• Experience interacting with tax authorities, competent authorities, external counsel, and economic advisors.

• Strong communication skills, with the ability to convey complex technical analyses into actionable recommendations for executives.

• Excellent stakeholder management, change leadership, program management, and team-development capabilities across different cultures and time zones.

• Daily hands-on experience with AI tools such as Gemini, Claude, or ChatGPT, including concrete examples of automation or redesign.

• Experience in building AI workflows or agents using tools like Claude Code or Codex is a strong advantage.

🏝️ Benefits

• Complimentary Gold-level Wellhub membership that provides access to onsite gyms and studios, digital fitness programs, and online wellness resources.

• Option to add up to three family members to the Wellhub membership.

• Comprehensive health, dental, and vision insurance.

• Telehealth services, care concierge, and an Employee Assistance Program.

• 401(k) matching program.

• Short-term and long-term disability insurance.

• Life insurance coverage.

• Flexible hybrid and remote work options.

• One-time reimbursement for home office equipment.

• Monthly allowance for expenses incurred while working from home.

• Flexible scheduling that aligns with team needs, time zones, and personal routines.

• Minimum of 25 days of paid time off per year, with an additional day accrued for each year of tenure up to 5 days.

• Annual holidays, including an extra day off for your birthday.

• Up to 12 weeks of fully paid parental leave for all new parents.

• Up to 18 weeks of paid leave for birthing parents.

• Part-time ramp-back period available for parents who give birth.

• Access to world-class career development platforms and interactive sessions.

• Personalized development roadmap tailored to individual career goals.

• Opportunities for internal career advancement.

• Continuous learning and feedback mechanisms.

• Eligibility for an annual bonus or sales incentive plan.

• Participation in a performance-based stock option program.