Job Description:

Rakuten International oversees 7 businesses with over 4,000 employees globally. The brand is recognized for its leadership and innovation in e-commerce, digital content, advertising, entertainment and communications, bringing the joy of discovery and access to more than 1 billion members across the world. Our teams deliver on the company's mission to delight merchants and customers through innovation, optimism, and teamwork.

Rakuten is seeking an experienced transfer pricing senior analyst to join our tax team to support Transfer Pricing for the Rakuten International North America businesses. The transfer pricing senior analyst will report to the transfer pricing manager and assist in the preparation of business unit specific projects, provide ad hoc support for a variety of tax related requests, help to ensure Rakuten has a tax efficient international structure that complies with transfer pricing and local country reporting requirements. We are looking for a hardworking individual who thrives in a fast-paced environment.

• 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.
• Knowledge in US international tax concepts (GILTI, BEAT, etc.) is a plus.

• 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.