Senior Manager - US Transfer Pricing

The role

The Senior Manager of Transfer Pricing will lead US-based transfer pricing operations and transactional planning. This role involves managing intercompany transactions, supporting international tax planning, and partnering with global business leaders.

What you will do

• Lead transactional planning initiatives and implement operational transfer pricing.
• Translate transfer pricing policies into intercompany calculations and journal-entry inputs.
• Partner with business operations and global transfer pricing team members.
• Lead operational studies to optimize adjustment processes and mitigate risks.
• Lead transfer pricing strategies for tangible asset transfers, intercompany services, and royalty models.
• Perform DEMPE analyses to support cross-border tax strategies.
• Support and represent Coupang in tax authority audits, APA, and MAP matters.
• Serve as the primary liaison to external advisers and Big 4 partners.
• Oversee external advisors in global documentation projects and benchmarking studies.
• Support international tax planning, restructuring, and compliance deliverables.

Required qualifications

• Bachelor’s degree in Accounting, Economics, Finance, or a related field
• 12+ years of transfer pricing experience in a Big 4 public accounting firm, law firm, or a large multinational technology company
• Deep technical expertise and applied knowledge of US transfer pricing regulations (IRC Section 482) and OECD Transfer Pricing Guidelines
• Proven operational and transactional planning transfer pricing experience
• Experience structuring complex intercompany transactions and assessing transfer pricing risk
• Experience integrating newly acquired companies or intangibles into global supply chains
• Hands-on experience supporting APA matters and defending transfer pricing positions during tax authority audits
• Ability to translate global tax disclosure requirements into operational reporting frameworks
• Advanced financial modeling skills
• Proficiency with managing large datasets

Nice to have

• Master’s degree
• CPA
• JD
• In-house experience at a large US multinational enterprise (MNE) in the tech sector
• Naturally curious mindset
• Highly self-motivated and comfortable operating with ambiguity
• Exceptional stakeholder management and communication skills
• Track record of driving process improvements
• High adaptability and resilience in a fast-paced, hyper-growth environment
• Demonstrated leadership capabilities

Benefits

• Annual bonus is 0-20% of the base salary
• Medical/Dental/Vision/Life, AD&D insurance
• Flexible Spending Accounts (FSA) & Health Savings Account (HSA)
• Long-term/Short-term Disability
• Employee Assistance Program (EAP) program
• 401K Plan with Company Match
• 18-21 days of the Paid Time Off (PTO) a year based on the tenure
• 12 Public Holidays
• Paid Parental leave
• Pre-tax commuter benefits

Before you apply

• Application Review - Job Fit Interview - Focus Interview – Offer
• The exact nature of the recruitment process may vary and may be changed
• Coupang has the right to rescind an offer if a candidate is found to have submitted false information

About the company

Coupang is an American technology company and one of the fastest-growing retail companies. It is a large global public company with a startup culture.