Full-Time

Sr. Transfer Pricing Analyst

Posted on 11/1/2024

Rakuten International

Rakuten International

1,001-5,000 employees

Consumer Software
Fintech
Consumer Goods
Entertainment

Compensation Overview

$65.5k - $112.6kAnnually

+ Bonus

Senior

Houston, TX, USA

Category
Risk Management
Finance & Banking

You match the following Rakuten International's candidate preferences

Employers are more likely to interview you if you match these preferences:

Degree
Experience
Requirements
  • Minimum 2 years of transfer pricing experience.
  • Excellent technical, analytical, research, written, presentation, organizational, project management, and communication skills.
  • Ability to multi-task, think independently, problem solve, and be detail-oriented.
  • Ability to provide exceptional service and exhibit a commitment to the timely completion of tasks.
  • Demonstrate commitment to continuous learning and work in a team environment.
Responsibilities
  • Research complex international tax issues and support the development and implementation of new tax strategies and programs.
  • Prepare remuneration policies for intercompany transactions for several U.S. business units (e.g. e-commerce, online content, advertising).
  • Prepare intercompany recharges and test appropriate transfer pricing policy application.
  • Interpret, evaluate, and use quantitative evidence in performing economic analysis on projects including identification of appropriate transfer pricing methods to price transactions.
  • Review benchmarks of comparable companies to confirm alignment with tested cross border transactions.
  • Draft and manage the collaboration with external advisors for BEPS-compliant transfer pricing documentation for business units.
  • Support U.S., Canadian, and other entities in submitting transfer pricing related returns.
  • Work with the legal team to ensure intercompany contracts are transfer pricing compliant.
  • Share latest transfer pricing updates to the relevant stakeholders.
  • Respond to inquiries and tax audit request in relation to transfer pricing matters and international tax audits.
  • Prepare documentation for the defense in different jurisdictions and advanced pricing arrangements (APAs) management.
  • Minimize transfer pricing risks, double taxation, withholding, and value added taxes related to intercompany charges and permanent establishment matters.
  • In-depth understanding of the latest IRS and OECD Transfer Pricing Guidelines as well as the ongoing work by the IRS, OECD, and other bodies that impact transfer pricing and the tax impact to the business units.
  • Collaborate with Transfer Pricing tax colleagues in EMEA and APAC on international tax projects, as appropriate.
  • Partner with cross-functional colleagues (Business, Finance, Legal, Accounting, etc.) to understand international business developments and provide subject matter expertise on various projects.
  • Support ad hoc international tax projects and global tax audits.
Desired Qualifications
  • Knowledge in US international tax concepts (GILTI, BEAT, etc.) is a plus.
Rakuten International

Rakuten International

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Company Stage

N/A

Total Funding

N/A

Headquarters

San Mateo, California

Founded

N/A

Simplify Jobs

Simplify's Take

What believers are saying

  • Rakuten's AI solutions could capture underserved niche markets, creating unique opportunities.
  • Unmanned delivery service in Tokyo may reduce costs and increase efficiency.
  • Strong demand for Rakuten's junk bonds indicates investor confidence in its growth.

What critics are saying

  • Competition in niche AI markets could impact Rakuten's growth and market share.
  • Unmanned delivery services may face regulatory challenges and public safety concerns.
  • Reliance on junk bonds could lead to financial instability if market conditions change.

What makes Rakuten International unique

  • Rakuten focuses on niche AI solutions, unlike major players like OpenAI or Google.
  • Rakuten's unmanned delivery service in Tokyo showcases innovation in urban logistics.
  • Rakuten's patent for aircraft landability control device highlights its aviation technology advancements.

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