Job Description

Team Introduction:
The Transfer Pricing ("TP") Team is part of the Tax Team which focus on transfer pricing matters not limited to TP planning, operational TP, TP compliance, TP model optimization, and tax audit assistance, etc.

ByteDance is seeking a Tax Transfer Pricing Specialist based in the Hong Kong office who will become an integral part of our global Tax Department. In this role, you will be assisting with transfer pricing matters across various business lines, including but not limited to TP planning, operational TP, TP compliance, TP model optimization, and tax audit assistance. This role will face some of the most dynamic challenges in transfer pricing and will have plenty of learning and growth opportunities. This will be a fully onsite role in Hong Kong.

Responsibilities:
- Independently lead the design, implementation, and continuous optimization of non–Mainland China transfer pricing policies for relevant business lines, coordinating across business units and related teams to establish an efficient transfer pricing framework and system.
- Manage the full end-to-end annual and quarterly transfer pricing settlement process, including data collection, model calculation, system entry, and intercompany transaction contract management.
- Conduct regular transfer pricing health checks, proactively identify key tax and operational risks, and propose and drive remediation actions.
- Provide professional transfer pricing advisory support to business, finance, and other relevant functions, including business model evolution, new project implementation, and organizational restructuring.
- Manage external advisors, lead the preparation and review of global transfer pricing documentation, and support responses to tax authority inquiries and audits.
- Collaborate with tax, legal, and finance teams to ensure consistency of intercompany transaction data; support data analysis and coordination for cost allocation arrangements, valuations, and related projects.
- Monitor global transfer pricing regulatory developments, conduct tax efficiency and profit allocation analyses, and support group-level tax planning initiatives.
- Perform other transfer pricing-related tasks and projects, including but not limited to systemization.