Senior Manager - US Transfer Pricing

Coupang · Seattle, USA

  • Senior
  • Full-time
  • Posted 2026-11-09
  • Confirmed live on 10 November 2026

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Job description

We exist to wow our customers. We know we’re doing the right thing when we hear our customers say, “How did I ever live without Coupang?” Born out of an obsession to make shopping, eating, and living easier than ever, we’re collectively disrupting the multi-billion-dollar commerce industry from the ground up. We are an American technology company and one of the fastest-growing retail companies that has established an unparalleled reputation for being a leading and reliable force in global commerce.

We are proud to have the best of both worlds — a startup culture with the resources of a large global public company. This fuels us to continue our growth and launch new services at the speed we have been since our inception. We are all entrepreneurial, surrounded by opportunities to drive new initiatives and innovations. At our core, we are bold and ambitious people that like to get our hands dirty and make a hands-on impact. At Coupang, you will see yourself, your colleagues, your team, and the company grow every day.

Our mission to build the future of commerce is real. We push the boundaries of what’s possible to solve problems and break traditional tradeoffs. Join Coupang now to create an epic experience in this always-on, high-tech, and hyper-connected world.

Role Overview

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.

What You Will Do

• 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.

Basic Qualifications

• 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 48

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