Principal Lead, Transfer Pricing

Bay Center Foods, LLC

Atlanta (GA)

On-site

USD 130,000 - 180,000

Full time

14 days+

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Job summary

Chick-fil-A, Inc. is seeking a Senior Transfer Pricing professional to develop and maintain the company’s global transfer pricing strategy and intercompany pricing models.

The role requires expert knowledge of US and international principles and close collaboration with Legal, Finance, and senior leadership. The position focuses on accordance with OECD guidelines, cross-border structuring, and ensuring defensible positions across multiple jurisdictions.

Qualifications

Expert knowledge of US and International Transfer Pricing Principles.
Strong understanding of International Tax concepts, legal entity structures, and global tax considerations.
Advanced technical research and analytical skills.
Strong business partnering and communication skills with ability to translate concepts for senior leaders.
Ability to independently lead highly complex Transfer Pricing matters with minimal oversight.
Ability to proactively identify risks and develop sustainable solutions.

Responsibilities

Own and evolve Chick-fil-A's global transfer pricing strategy, adapting intercompany pricing models to expansion and evolving regulations.
Evaluate arm's length nature of intercompany transactions, forming defensible positions across jurisdictions.
Lead technical analysis and decision-making for transfer pricing matters, interpreting OECD guidance and local rules.
Partner with Legal to structure intercompany agreements reflecting pricing policies and audit defensibility.
Collaborate with Finance, Tax, and business stakeholders to evaluate transactions and ensure consistent reporting.
Drive risk identification and audit readiness with robust documentation and defensible positions.
Advise senior leadership on transfer pricing implications of business decisions and growth plans.
Manage external advisors and benchmarking studies to ensure alignment with company risk tolerance.

Skills

Transfer Pricing Strategy

OECD Guidelines

Intercompany Transactions

Global Tax Compliance

Analytical Thinking

Cross-functional Leadership

Education

Bachelor's Degree

Accounting/Finance/Economics

Job description

How We Work At Chick-fil-A

Chick-fil-A, Inc. ('Chick-fil-A' or 'the Company') Staff members play a vital role in achieving our strategic goals by developing their skills, fostering inclusive teamwork, and embracing innovation. All Staff are expected to contribute to a compelling future by inspiring and motivating those around them. Growth and development are essential at Chick-fil-A. We want Staff to seek new perspectives and adopt new methods to drive continuous improvement and adaptation to evolving business needs. Lastly, we ask Staff to seek wisdom, expect the best, accept responsibility, respond with courage, and think others first.

Our Flexible Futures Model offers a healthy mix of working in person (currently a minimum of 8-10 days per month) and virtually, strengthening key elements of the Chick-fil-A culture by fostering collaboration and community.

Overview

The Professional/Individual Contributor Staff member is responsible for performing work responsibilities, building relationships, and sharing expertise and experience as he/she contributes to specific bodies of work, builds connections, and optimizes performance.

The Chick-fil-A Tax Department is responsible for tax compliance, technology, special projects, research and audit defense functions for independently-owned franchised restaurants and corporate activities. We exist to provide tax planning, regulatory reporting and consulting to stakeholders, governments, external auditors and business leaders. As we grow in complexity and global footprint, we seek to influence business decisions, reduce tax liability and mitigate risk.

This role is responsible for developing and maintaining Chick-fil-A's global transfer pricing strategy, ensuring intercompany transactions are aligned with business operations and international tax requirements. The position serves as the company’s subject matter expert on transfer pricing, providing technical leadership, advising on complex cross-border matters, and establishing defensible positions across jurisdictions. The role also partners with business, Finance, Legal, and external advisors to manage risk, support strategic growth, and maintain globally consistent and audit-ready transfer pricing policies.

Responsibilities

Own and evolve Chick-fil-A's global transfer pricing strategy, proactively adapting intercompany pricing models in response to business expansion, changing operating models, and evolving global tax regulations

Evaluate and determine the arm's length nature of intercompany transactions(e.g., royalties, management fees, and other cross-border arrangements), forming defensible positions that align financial outcomes with operational substance across multiple jurisdictions

Lead technical analysis and decision-making for transfer pricing matters, including interpreting OECD guidance and local country rules, assessing how changes impact existing policies, and determining appropriate positions where guidance is ambiguous or evolving

Partner with Legal to structure and review intercompany agreements, ensuring contractual terms accurately reflect pricing policies and underlying business arrangements, and are aligned with global transfer pricing strategy and audit defensibility requirements

Collaborate with Finance, Tax, and business stakeholders to evaluate intercompany transactions, recommend allocation methodologies, and ensure consistent and supportable reporting across jurisdictions

Drive proactive risk identification and audit readiness, including developing robust supporting documentation, anticipating areas of challenge, and ensuring positions are consistent and defensible across multiple country tax authorities

Advise senior leadership on transfer pricing implications of business decisions, including expansion into new markets, entity structuring, and changes in operating models, balancing tax efficiency, risk, and operational practicality

Manage and direct external advisors and benchmarking studies, critically evaluating conclusions and ensuring outputs are aligned with Chick-fil-A's facts, strategy, and risk tolerance - not simply accepted at face value

Required Qualifications (Knowledge, Skills, & Abilities)

Expert knowledge ofUS and International Transfer Pricing Principles, including OECD Guidelines and arm’s length standards in cross-border intercompany transactions

Strong understanding of International Tax concepts, Legal entity structures, intercompany agreements, and global tax controversy considerations

Advanedtechnical research and analytical skills

Strong business partnering and communication skills with ability to translate technical concepts intopracfticalrecommendations for senior leaders

Ability to independently lead highly complex Transfer Pricing matters with minimal oversight and exercise sound judgment in areas where guidance is ambiguous