Transfer Pricing Senior Manager (Multiple Positions)

Responsibilities

About ByteDance
Founded in 2012, ByteDance's mission is to inspire creativity and enrich life. With a suite of more than a dozen products, including TikTok, Helo, and Resso, as well as platforms specific to the China market, including Toutiao, Douyin, and Xigua, ByteDance has made it easier and more fun for people to connect with, consume, and create content.


Why Join Us
Creation is the core of ByteDance's purpose. Our products are built to help imaginations thrive. This is doubly true of the teams that make our innovations possible.
Together, we inspire creativity and enrich life - a mission we aim towards achieving every day.
To us, every challenge, no matter how ambiguous, is an opportunity; to learn, to innovate, and to grow as one team. Status quo? Never. Courage? Always.
At ByteDance, we create together and grow together. That's how we drive impact - for ourselves, our company, and the users we serve.
Join us.

About the Team
Our team plays a crucial role in ensuring the company’s success. We seek people who are willing to learn and put in the effort to solve problems. Our challenges are not your regular day-to-day problems - you’ll be part of a team that’s developing new solutions to new challenges. It’s working fast, at scale, and we’re making a difference. We are looking for talents to join us on this exciting journey!


Responsibilities
- Manage operational transfer pricing (TP) within the Americas Region by monitoring, reviewing, and supporting the implementation of TP processes and controls on a periodical basis.
- Manage and maintain TP compliance and planning in the Americas region by working with external consultants to prepare, manage, and maintain TP compliance files for the entities in the Americas including TP Masterfile, TP documentation, local file, and Country-by-country report.
- Conduct internal TP risk assessment and recommend tax compliance enhancement opportunities by utilizing both accounting and business information to evaluate the effectiveness of the current TP model from a factual point of view.
- Monitor and analyze proposed and newly enacted TP legislation, regulations and judicial decisions that impact the Company’s operations and financial Positions.
- Understand the calculations in the TP analysis by using a series of financial analysis metrics, economic and statistical knowledge, as well as the understanding of local tax laws.
- Respond to internal and external tax inquiries and assist business partners with resolving TP issues.
- Understand the business development and provide any TP concerns based on local tax laws.
- Provide preliminary answers with respect to any business model that needs TP judgement.
- Manage and maintain intercompany legal agreements.
- Manage TP planning projects including IP valuation, entity valuation, and intercompany financing transactions.
- Understand the overall tax efficiency of the current business model and identify any business model change that can improve the tax efficiency.
- Implement the model change through establishing work plan, project management, and measurement of performance to achieve risk mitigation or higher tax efficiency.
- Lead functional interviews and maintain the documentation of functional analyses and TP Policies.
- Participate in regional or industry tax forum host by accounting firms or AICPA.

Qualifications

Qualifications
Must have a Master’s degree in Accounting, Taxation, Economics, Finance, Management, Business, Mathematics, Statistics, or a related field, and 5 years of related work experience; OR a Bachelor’s degree in Accounting, Taxation, Economics, Finance, Management, Business, Mathematics, Statistics, or a related field, and 7 years of related work experience, out of which
5 years must be post-bachelor’s, progressive related work experience.

Of the required experience, must have 5 years of experience in each of the following:
- Transfer pricing documentation;
- Transfer pricing planning, Advance Pricing Agreement (APA), and controversy support;
- Economic modeling and intellectual property valuation;
- Conducting company’s internal transfer pricing risk assessments and recommending tax compliance enhancement opportunities;
- Preparing functional and financial analyses to audit or to plan existing or potential transfer pricing policies; and
- Monitoring and analyzing proposed and enacted transfer pricing legislations, regulations, and judicial decisions in the U.S. that impact the company’s operations and financial positions.

TRAVEL REQUIREMENT: International travel up to 15% required.

Type: Full time, 40 hours/week
Location: San Jose, CA
Salary Range: $137030 - $244800 per year

To Apply, click the apply button below. Contact lpresumes@bytedance.com if you have dif