Tax Director, 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

We are seeking a Tax Director to build and lead the company's transfer pricing strategy and operations, ensuring compliance with international tax laws and optimizing transfer pricing policies across multiple jurisdictions. You are a strategic and analytical leader with deep knowledge of transfer pricing regulations, risk management, and have the ability to develop scalable processes in a fast-growing, dynamic environment. As the company expands globally, you will be responsible for designing and implementing transfer pricing policies that align with the company’s operational goals while managing tax-related risks.

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:

• Design and implement a global transfer pricing strategy aligned with the company’s growth objectives and operational structure.
• Establish policies and frameworks to ensure transfer pricing compliance across all regions, aligning with local and international regulations, including OECD guidelines.
• Identify opportunities for operational efficiency, cost savings, and tax optimization through effective transfer pricing policies.
• Oversee the preparation and maintenance of transfer pricing documentation and local files for all applicable jurisdictions, ensuring timely and accurate submissions.
• Develop transfer pricing reports, including master files, local files, and country-by-country reports, to satisfy statutory requirements.
• Lead compliance with Base Erosion and Profit Shifting (BEPS) Action Plans and other international tax initiatives impacting transfer pricing.
• Leverage technology and data analytics to streamline transfer pricing compliance, reporting, and analysis processes.
• Design scalable processes and systems that can grow with the company’s international footprint, improving accuracy, transparency, and efficiency in transfer pricing management.
• Support transfer pricing due diligence and integration for mergers, acquisitions, and other expansion activities.
• Assess and advise on transfer pricing implications related to business model changes, restructurings, or the launch of new products and services.
• Monitor transfer pricing risk, assess potential exposures, and develop mitigation strategies for high-risk jurisdictions.
• Work closely with finance, accounting, legal, and operations teams to ensure that transfer pricing policies are effectively implemented and aligned with the company’s operational and financial reporting.

You might thrive in this role if you have:

• A Bachelor's degree in Economics, Accounting, Finance, or related field. An advanced degree (eg, Master’s in Tax, MBA, or Economics) is preferred.
• 12+ years of progressive experience in tax roles with significant exposure to multinational environments (20+ foreign entities).
• In-depth knowledge of transfer pricing regulations, compliance requirements, and global tax standards. 
• Previous experience in a law firm, Big Four firm, and/or high-growth pre-IPO companies.
• Proven ability to manage complex tax issues and provide effective tax strategies.
• Strong communication skills, with the ability to explain tax concepts to non-tax stakeholders.
• Experience with tax software and systems, particularly NetSuite, is a plus.
• Strong analytical skills and experience in a fast-paced, dynamic environment.

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 do not discriminate on the basis of race, religion, national origin, gender, sexual orientation, age, veteran status, disability or any other legally protected status. 

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For US Based Candidates: Pursuant to the San Francisco Fair Chance Ordinance, we will consider qualified applicants with arrest and conviction records.

We are committed to providing reasonable accommodations to applicants with disabilities, and requests can be made via this link.

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At OpenAI, we believe artificial intelligence has the potential to help people solve immense global challenges, and we want the upside of AI to be widely shared. Join us in shaping the future of technology.