Senior Manager - US Transfer Pricing

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 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 Qualifications

• 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.

Pay & Benefits

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.

General Description of All Benefits

• Annual bonus is 0-20% of the base salary
• Medical/Dental/Vision/Life, AD&D insurance
• Flexible Spending Accounts (FSA) & Health Savings Account (HSA)
• Long-term/Short-term Disability
• Employee Assistance Program (EAP) program
• 401K Plan with Company Match
• 18-21 days of the Paid Time Off (PTO) a year based on the tenure
• 12 Public Holidays
• Paid Parental leave
• Pre-tax commuter benefits

General Description of Other Compensation

“Other Compensation” includes, but is not limited to, bonuses, equity, or other forms of compensation that would be offered to the hired applicant in addition to their established salary range or wage scale.

Recruitment Process

• Application Review - Job Fit Interview - Focus Interview – Offer
• The exact nature of the recruitment process may vary according to the specific job and may be changed due to scheduling or other circumstances.
• Interview schedules and the results will be informed to the applicant via the e-mail address submitted at the application stage

Details to Consider

• This job posting may be closed prior to the stated end date for application if all openings are filled.
• Coupang has the right to rescind an offer of employment if a candidate is found to have submitted false information as part of the application process.
• Those eligible for employment protection (recipients of veteran’s benefits, the disabled, etc.) may receive preferential treatment for employment in accordance with applicable laws.

Privacy Notice

• Your personal information will be collected and managed by Coupang as stated in the Application Privacy Notice located below: https://www.coupang.jobs/privacy-policy/

Coupang is an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to actual or perceived race (including traits historically associated with race, including but not limited to hair texture and protective hair styles), color, religion, religious creed (including religious dress and grooming practices), sex or gender (including pregnancy, childbirth, breastfeeding, and medical conditions related to pregnancy, childbirth or breastfeeding), gender identity, gender expression, sexual orientation, ,ancestry, national origin (including language use restrictions), age (40 and over), physical or mental disability, medical condition, genetic information, HIV/AIDS or Hepatitis C status, family status (including but not limited to marital or domestic partnership status), military or veteran status, use of a trained dog guide or service animal, political activities or affiliations, ancestry, citizenship, family and medical leave status, status as a victim of any violent crime, or any other characteristic or class protected by the laws or regulations in the locations where we operate. Coupang is also committed to providing a safe work environment for its employees and its consumers. If you need assistance and/or a reasonable accommodation in the application of recruiting process due to a disability, please contact us at [email protected]

Job Requisition ID: R0081650