Senior Manager - US Transfer Pricing at Coupang · LumiJobs

Responsibilities

As Coupang continues to scale rapidly and expand into new global markets and business lines, we are seeking a highly capable Senior Manager of Transfer Pricing to lead our US-based transfer pricing operations and transactional planning. This role is highly cross-functional, requiring you to identify risks and opportunities, operationalize transfer pricing changes, and seamlessly partner with business leaders to translate complex operating models into defensible tax positions. Uniquely, this position requires a generalist mindset: while your primary focus is transfer pricing, approximately 20% of your time will be dedicated to supporting broader international tax planning and compliance efforts.
Operational & Transactional Transfer Pricing: Lead transactional planning initiatives and implement operational transfer pricing for a broad range of intercompany transactions. Translate transfer pricing policies into recurring intercompany calculations, true-ups, journal-entry inputs, and period-end close schedules. Embed transfer pricing policies into high-volume, systems-driven commerce environments.
Cross-Functional & Global Leadership: Partner directly with business operations and collaborate closely with global transfer pricing team members outside the US to scale transfer pricing frameworks as Coupang expands into different businesses and markets, ensuring audit readiness and systemic consistency. Lead operational studies focused on optimizing adjustment processes to eliminate resource bottlenecks, while actively mitigating customs revaluation and Permanent Establishment (PE) risks.
Intercompany Transactions & Intellectual Property: Lead the transfer pricing strategies surrounding tangible asset transfers, intercompany services, and royalty models. Advise on global intangible alignment and perform DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) analyses to support cross-border tax strategies and IP integrations. Assist with implementing financial transactions, including debt capacity analyses for intercompany financing arrangements.
Controversy & APA/MAP Representation: Support and represent Coupang in tax authority audits, Advance Pricing Agreements (APA), and Mutual Agreement Procedure (MAP) matters by preparing technical analyses, economic exposure assessments, and negotiation support.
External Partner Management & Global Compliance: Serve as the primary liaison to external advisers and Big 4 partners. Direct and oversee external Big 4 advisors in the execution of global documentation projects, comparable company searches, and benchmarking studies, as well as the preparation of Master Files and Local Files. Strengthen global compliance and risk management by monitoring OECD requirements, BEPS, Pillar Two, and Country-by-Country Reporting (CbCR).
International Tax Planning (20%): Apply a generalist mindset to support international tax planning, restructuring, and compliance deliverables outside of the standard transfer pricing scope. Support quarterly and annual close and financial reporting workflows, including ASC 740 and FIN 48 analyses, provision memoranda, and transfer pricing reserve calculations.

Qualification

Bachelor’s degree in AccountingStrong ability to translate complexDemonstrated leadership capabilitiesGeneral Description of All Benefits

Required

Bachelor’s degree in Accounting, Economics, Finance, or a related field (Master’s degree, CPA, or JD preferred).
12+ years of transfer pricing experience in a Big 4 public accounting firm, law firm, or a large multinational technology company. In-house experience at a large US multinational enterprise (MNE) in the tech sector is strongly preferred.
Deep technical expertise and applied knowledge of US transfer pricing regulations (IRC Section 482) and OECD Transfer Pricing Guidelines, with a proven ability to translate these frameworks into practical, business-aligned solutions.
Proven operational and transactional planning transfer pricing experience, including maintaining and updating calculation models and intercompany agreements.
Demonstrated experience structuring complex intercompany transactions, assessing transfer pricing risk, and 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.
Strong ability to translate complex, evolving global tax disclosure requirements into compliant operational reporting frameworks.
Advanced financial modeling skills and proficiency with managing large datasets.

Preferred

A naturally curious mindset with a drive to dig deep into evolving business models, ask critical questions, and understand the "why" behind the data.
Highly self-motivated and comfortable operating with ambiguity; able to work autonomously, take end-to-end ownership of projects, and thrive without direct supervision in an entrepreneurial environment.
Exceptional stakeholder management and communication skills, with the ability to distill complex transfer pricing and international tax concepts into clear, actionable business advice for non-tax leaders in Finance, Legal, and Operations.
A track record of driving process improvements, leveraging technology and automation to streamline workflows, scale operations, and eliminate manual inefficiencies.
High adaptability and resilience in a fast-paced, hyper-growth environment, capable of pivoting quickly and maintaining a strategic outlook as Coupang enters new global markets or launches new business lines.
Demonstrated leadership capabilities, with a proven ability to mentor and coach team members, guide cross-functional stakeholders without formal authority, and act as a trusted strategic thought partner to executive leadership.
Our compensation reflects the cost of labor across several US geographic markets. At Coupang, your base pay is one part of your total compensation. The base pay for this position ranges from $155,000/year in our lowest geographic market to $267,000/year in our highest geographic market. Pay is based on several factors including market location and may vary depending on job-related knowledge, skills, and experience.

Senior Manager - US Transfer Pricing

Responsibilities

Qualification

Required

Preferred

Benefits

Company

Coupang

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