Transfer Pricing Tax Director

Company Description
It all started in sunny San Diego, California in 2004 when a visionary engineer, Fred Luddy, saw the potential to transform how we work. Fast forward to today - ServiceNow stands as a global market leader, bringing innovative AI-enhanced technology to over 8,100 customers, including 85% of the Fortune 500®. Our intelligent cloud-based platform seamlessly connects people, systems, and processes to empower organizations to find smarter, faster, and better ways to work. But this is just the beginning of our journey. Join us as we pursue our purpose to make the world work better for everyone.
Job Description
The Transfer Pricing Tax Director has a key role in the Tax Organization reporting to the Senior Director of International Tax. This position will lead the transfer pricing function and have responsibility for providing analysis and support for the development, implementation and defense of our group transfer pricing policy. This role will serve as a strategic business partner in advising and supporting the global tax team in transfer pricing related issues, policies and procedures. You must have the ability to operate independently in a fast-paced environment and to work closely and proactively with numerous functional teams across our organization. This position will be based in Santa Clara, California, USA.
What You Get To Do In This Role

• Be a key member of the global tax leadership team. Develop excellent working relationships with other members of the tax leadership team to align on tax strategy, processes and goals.
• Establish, maintain and communicate transfer pricing policies and procedures to ensure consistent application across our global operations.
• Build and execute efficient operational transfer pricing processes and metrics.
• Partner with Digital Transformation and systems teams to design and implement technology solutions that automate and optimize operational transfer pricing processes, ensuring scalability, accuracy, and compliance.
• Work closely with cross-functional business partners to maintain a deep understanding of our supply chain, legal entity operations, transaction flows, risks and functions.
• Support preparation and/or review of global transfer pricing documentation for tax compliance and tax audit defense purposes in all jurisdictions where the Company operates, including functional analysis, intercompany agreements, Master File and Local Files, etc.
• Provide support for tax audit and tax controversy matters, including Advanced Pricing Agreement and double tax relief through Mutual Agreement Procedures. Assist with the preparation of replies to tax authority information requests on transfer pricing issues.
• Support M&A and tax restructuring projects from a transfer pricing perspective.
• Provide transfer pricing guidance and support related to tax provision, FIN 48 analysis for transfer pricing positions, operational transfer pricing execution, forecasting, and scenario modeling. This includes developing robust methodologies, ensuring accurate financial reporting, and aligning transfer pricing strategies with overall business objectives.
• Monitor changes in global transfer pricing laws and communicate those changes to the appropriate stakeholders within the organization.
• Be highly organized and be able to effectively manage and analyze data for transfer pricing purposes.

Qualifications
To be successful in this role you have:

• Experience in leveraging or critically thinking about how to integrate AI into work processes, decision-making, or problem-solving. This may include using AI-powered tools, automating workflows, analyzing AI-driven insights, or exploring AI's potential impact on the function or industry.
• 12+ years of progressive transfer pricing experience in public accounting and/or industry; SaaS experience with large U.S.-based multinationals is a plus.
• Advanced degree in Tax, Law, or Economics is preferred.
• Deep knowledge of OECD guidelines, U.S. and global transfer pricing regulations, and compliance requirements.
• Proven technical expertise in planning, implementing, and managing global transfer pricing projects.
• Strong skills in research, analysis, and documentation of complex transfer pricing issues.
• Experience with tax PPA accounting, FIN 48 analysis, operational transfer pricing execution, forecasting, and modeling.
• Strong analytical capabilities with financial modeling and economic analysis experience.
• Proven ability to collaborate with Digital Transformation, or systems teams to implement technology solutions for transfer pricing processes.
• Familiarity with ERP systems (SAP) and tax technology tools; experience with automation and data analytics platforms is a plus.
• Effective partnership with cross-functional stakeholders and ability to clearly communicate complex tax issues to non-tax audiences.
• Solid project management skills and experience managing internal and external relationships.
• Proficient with financial systems/applications, strong Excel skills in data compilation and aggregation.
• Strong critical thinking skills and attention to detail

For positions in this location, we offer a base pay of $189,100 - $331,000, plus equity (when applicable), variable/incentive compensation and benefits. Sales positions generally offer a competitive On Target Earnings (OTE) incentive compensation structure. Please note that the base pay shown is a guideline, and individual total compensation will vary based on factors such as qualifications, skill level, competencies, and work location. We also offer health plans, including flexible spending accounts, a 401(k) Plan with company match, ESPP, matching donations, a flexible time away plan and family leave programs. Compensation is based on the geographic location in which the role is located and is subject to change based on work location.
Additional Information
Work Personas
We approach our distributed world of work with flexibility and trust. Work personas (flexible, remote, or required in office) are categories that are assigned to ServiceNow employees depending on the nature of their work and their assigned work location. Learn more here . To determine eligibility for a work persona, ServiceNow may confirm the distance between your primary residence and the closest ServiceNow office using a third-party service.
Equal Opportunity Employer
ServiceNow is an equal opportunity employer. All qualified applicants will receive consideration for employment without regard to race, color, creed, religion, sex, sexual orientation, national origin or nationality, ancestry, age, disability, gender identity or expression, marital status, veteran status, or any other category protected by law. In addition, all qualified applicants with arrest or conviction records will be considered for employment in accordance with legal requirements.
Accommodations
We strive to create an accessible and inclusive experience for all candidates. If you require a reasonable accommodation to complete any part of the application process, or are unable to use this online application and need an alternative method to apply, please contact [email protected] for assistance.
Export Control Regulations
For positions requiring access to controlled technology subject to export control regulations, including the U.S. Export Administration Regulations (EAR), ServiceNow may be required to obtain export control approval from government authorities for certain individuals. All employment is contingent upon ServiceNow obtaining any export license or other approval that may be required by relevant export control authorities.
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