Director, Transfer Pricing

San Jose, California Requisition Number R0037059

The Company

We are a company that inspires passion, courage and imagination, where you can be part of the team shaping the future of global commerce! We shape how millions of people buy, sell, connect, and share around the world. If you’re interested in joining a purpose driven community that is dedicated to building an ambitious and inclusive work environment, join eBay – a company you can be proud to be a part of!

eBay Inc. (NASDAQ: EBAY) is a global commerce leader. Collectively, we connect millions of buyers and sellers around the world, empowering people and creating opportunity through Connected Commerce. Founded in 1995 in San Jose, Calif., eBay is one of the world’s largest and most vibrant marketplaces for discovering great value and unique selection.

The Opportunity

eBay’s tax department in San Jose is looking for an experienced transfer pricing professional to lead its global transfer pricing functions. As part of the global tax operations team, this high-profile role will be instrumental in formulating challenging and strategic transfer pricing framework in a complex and evolving transfer pricing landscape under BEPS 2.0 environment. The director of Transfer Pricing will also be responsible for the development of the transfer pricing structure for eBay’s new managed payments business to meet legal, tax, and regulatory requirements. This position will be actively engaged in the transformation of eBay’s tax function by achieving operational efficiency while improving compliance via automation and strong execution.

You will have management and mentoring responsibility for the work of 3+ in-house TP specialists.

What You’ll Do


  • Partner with business units, global functional teams and regional management to execute develop and execute new transfer pricing structure to facilitate business initiatives, corporate restructuring, and M&A activity, etc.
  • Recognize potential transfer pricing and tax issues in complex business matters and develop creative business/tax solutions without creating undue tax risk.
  • Conduct economic and financial analysis to optimize TP results within a holistic TP framework that looks well beyond single sided approaches.
  • Support and undertake legal entity valuations and IP valuation related to M&A activities.
  • Identify, develop and execute, together with business teams where appropriate, planning opportunities that benefit operating profit.

Controversy Resolution & Risk Management

  • Defend eBay’s transfer pricing and international tax positions in audits by the tax authorities and financial statement auditors.
  • Act as the subject matter expert in the preparation and negotiation of unilateral and bilateral APA’s with tax authorities.
  • Support the pursue of mutual agreements with Competent Authority on transfer pricing related matters.
  • Identify and evaluate transfer pricing risks resulting from changes in business practices and global tax landscape and propose solutions to mitigate these risks.
  • Ensure alignment of transfer pricing positions globally in order to successfully defend and provide consistency in technical analysis/position.

Provision & Compliance

  • Build and maintain the transfer pricing forecasting models (including cost sharing, management services, and distributor services) used for tax provision purposes.
  • Assist with FIN 48 analysis and uncertain tax positions related to transfer pricing.
  • Supervise the preparation of key contemporaneous transfer pricing documentation reports by outside service providers and internal TP staff.
  • Support the compilation and reporting of Country-by-Country report and Master File.
  • Develop, update, and maintain intercompany agreements.

Operational TP

  • Lead our efforts to develop a robust and yet efficient Operational TP environment.
  • Build and maintain automated transfer pricing models to calculate, record, and forecast transfer pricing payments.
  • Support and drive elements of our Operational TP and Tax Innovation/Automation projects.
  • Collaborate with teams in tax, finance and accounting, financial reporting, and the business to ensure accurate documentation and effective Operational TP.

What You’ll Need

  • Bachelor's degree required, advanced degree is a plus.
  • Deep understanding of transfer pricing principles, economic theory, TP regulations, and recent OECD development.
  • Well-developed interpersonal skills and leadership experience.
  • Prior in-house transfer pricing experience is a major plus.
  • Strong analytical and problem-solving skills.
  • Strong technical abilities including financial modelling skills.
  • Strong communication and project management skills.
  • Ability to influence cross-functional and cross-divisional teams outside direct span of control.
  • Ability to develop, mentor, coach and lead staff ensuring the development of employees.

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eBay Inc. is an equal opportunity employer.  All qualified applicants will receive consideration for employment without regard to race, color, religion, national origin, sex, sexual orientation, gender identity, veteran status, and disability, or other legally protected status.  If you are unable to submit an application because of incompatible assistive technology or a disability, please contact us at  We will make every effort to respond to your request for disability assistance as soon as possible.

For more information see:

EEO is the Law Poster

EEO is the Law Poster Supplement

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