Overview

Entity: Finance Job Family Group: Tax Group 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. You will provide technical input to these groups to help shape the strategic direction of initiatives, ensuring safe and compliant operations, and supporting appropriate audit defence for the TP positions and strategies being implemented. This role will also support tax planning, tax compliance, and tax audits and appeals as they relate to BP's Upstream, Downstream and Supply, Trading & Shipping activities, as well as centralised functional support teams (e.g. Technology, Procurement). The focus is primarily on the US, with scope also encompassing other jurisdictions. This role supports bp's cross-border, intergroup transactions, and associated US compliance and audit defense activities. Given the materiality of cross border activities undertaken by bpUS companies, along with the need to ensure ongoing, safe compliant TP operations along with appropriate TP audit defense the economic dimensions of this role are materially well within the tens of billions of dollars per year. This is a fantastic opportunity to bring your transfer pricing expertise to life in a real-world, practical and commercial environment!Key accountabilities and challenges You will work with personnel, transactions and data where US tax requirements are not the primary consideration, often across complex operations and deals spanning multiple businesses and functions over extended timelines. This includes interpreting incomplete or imperfect data, anticipating impacts that are not always readily apparent, and providing expert recommendations to solve complex problems. Operating in a fast-paced and evolving area of taxation and reporting, this role requires strong technical expertise, a sound understanding of business operations, and the ability to deliver timely advice and decisions-often within short timeframes and with potentially significant impact. Coordination and collaboration with diverse teams across multiple jurisdictions will be key, frequently without face-to-face interaction. This includes coaching and supporting colleagues globally, aligning input from multiple locations, and ensuring shared understanding of US tax requirements where changes to processes may be required. The role includes supporting and leading transfer pricing initiatives, audits, compliance, and planning activities across the US, Canada and Latin America. This includes analysing proposed legislation and regulations, advising Tax Management and business-facing tax planners on potential impacts, and ensuring compliance with evolving requirements. You will manage risk and drive efficient, standardised and simplified operations, while identifying continuous improvement opportunities and reducing complexity. This includes developing subject matter expertise in BP's related party arrangements and ensuring tax requirements are clearly understood and met. Leadership and support of technical transfer pricing activities are required, including drafting and reviewing tax-related contractual language, maintaining and supporting Advanced Pricing Agreements (APAs), contributing to future APA and Competent Authority processes, and supporting ongoing business proposals, transactions and initiatives. You will lead US transfer pricing audit activities, including audit strategy, technical positions, IDR management and direct engagement with IRS examination teams, as well as approving settlements within delegated authority and conducting transfer pricing risk assessments across the bp Group. Ensuring accurate and complete reporting of c