Tax Senior Manager - Transfer Pricing

Job Description

The Tax Senior Manager - Transfer Pricing (TP) is the senior advisor on United States ("US") TP matters, including tax treaty provisions and the US implications of TP policies established by the OECD, UN and other international bodies. The role holder will work with other global members of the TP Team, senior members of Group Tax and their teams, our various US businesses, and bp’s Finance organisation.

It provides technical input to these groups to shape the strategic direction of initiatives, ensuring safe and compliant operations and supporting audit defence for TP positions and strategies. The role also supports tax planning, compliance and audits and appeals relating to BP’s upstream, downstream and supply, trading & shipping activities, and centralised support teams. The focus is primarily on the US, with scope also encompassing other jurisdictions.

It supports bp’s cross‑border, intergroup transactions and associated US compliance and audit defence activities, with materiality within tens of billions of dollars per year.

Work with personnel, transactions and data where US tax requirements are not the primary consideration, across complex operations and deals spanning multiple businesses and functions over extended timelines. Interpret incomplete data, anticipate impacts, and provide expert recommendations. Operate in a fast‑paced, evolving area requiring strong technical expertise, sound business understanding and the ability to deliver timely advice within short time frames. Coordinate and collaborate across jurisdictions, coach and support global colleagues, and align input from multiple locations.

Lead and support transfer pricing initiatives, audits, compliance and planning across the US, Canada and Latin America. Analyse legislation, advise tax management, and ensure compliance. Manage risk, drive efficient operations, identify continuous improvement, reduce complexity, and develop subject‑matter expertise in BP’s related‑party arrangements. Draft and review tax‑related contractual language, maintain APAs, contribute to APA and competent authority processes, and support business proposals.

Lead US transfer pricing audit activities, including strategy, technical positions, IDR management, engage with IRS teams, approve settlements, and conduct risk assessments across the group. Ensure accurate reporting of cross‑border intergroup transactions in the US consolidated federal income tax return, working with the US Tax Operations Team and continuously improving processes. Lead management of external US transfer pricing advisors and deliver high‑quality, audit‑ready documentation.

Collaborate with the global TP team to develop, implement and sustain optimised strategies and ensure compliance with US rules, regulations and IRS guidance.

• Significant transfer pricing advisory experience.
• Relevant qualifications in tax, accounting, economics, law or a related financial subject area (or equivalent experience).
• Strong technical expertise in US transfer pricing laws and regulations, including a working knowledge of OECD guidelines and an understanding of federal income tax as applied to transactions, legal entity structures and international operations. Experience in US corporate, partnership or international taxation is a strong advantage.
• Strong financial capability, including modelling expertise and excellent analytical skills.
• Ability to work effectively across multi‑cultural environments with a commitment to safe, compliant and reliable operations, and to fostering a culture of mutual trust, respect and inclusion aligned with bp’s values & behaviours.
• Strong written and verbal communication skills, with the ability to represent bp effectively with governmental agencies.
• Ability to work independently and manage cross‑border projects.
• Proficiency in digital and analytical tools, including AI‑enabled solutions, Power BI, and the Microsoft Office suite.

Base salary range: $180,000 – $225,000. Eligible for US Benefits – Core, including paid vacation, paid holidays, discretionary annual bonus program, long‑term incentive program, 401(k) matching, pension, health, vision, dental, life and disability insurance. Up to 10% travel required. Hybrid office/remote work. No relocation assistance.

We are an equal opportunity employer. We do not discriminate on the basis of protected characteristics like race, religion, color, sex, national origin, sexual orientation, veteran status or disability status. Individuals with an accessibility need may request an adjustment/accommodation related to bp’s recruiting process. If you are selected for a position and depending on your role, your employment may be contingent upon adherence to local policy, including pre‑placement drug screening, medical review of physical fitness and background checks.