Tax Senior Manager

Entity: Finance Job Family Group: Tax Group Job Description: This is an exciting opportunity for a senior tax professional looking for a fast paced and dynamic role that will help shape the strategic direction of high-value business initiatives! Accountable for tax planning, compliance, audits, appeals, and policy matters across bp’s US and cross-border Upstream and Downstream activities in the Americas, the role holder will partner with colleagues across Group Tax, Upstream, Downstream, Finance, Legal, and Treasury to deliver commercially focused tax advice. The role will provide tax leadership, supporting investments, transactions, restructurings, financing activities, compliance, and audit matters. Operating at scale, the role is responsible for ensuring compliant, commercially sound tax outcomes across assets, revenues, taxes, credits, and exposures measured in the billions of dollars. Key responsibilities and Accountabilities: Ensure that Upstream and Downstream business activities are conducted in compliance with applicable US federal income tax rules, regulations, administrative guidance, case law, and relevant international tax principles. Provide timely, practical tax advice on investments, commercial arrangements, operating model changes, supply chains, restructurings, joint ventures, acquisitions, divestments, farm-ins, farm-outs, and other material business initiatives. Advise on US domestic matters, international tax matters, centralized funding and treasury-related matters. Manage and support debt-equity analyses for tax purposes, including assessment of instrument terms, commercial rationale, legal documentation, repayment capacity, market support, withholding tax consequences, and audit-defensible technical positions. Advise on interest deductibility, thin capitalization, earnings stripping, hybrid mismatch, anti-hybrid, base erosion, withholding tax, and treaty eligibility rules relevant to internal and external funding arrangements. Coordinate with Treasury, Legal, Group Tax colleagues, and other subject matter experts as needed to ensure funding structures are commercially effective, tax efficient, aligned with arm’s-length principles, appropriately documented, and reflected in reporting. Review tax treaty positions and beneficial ownership considerations for cross-border interest, guarantee fee, dividend, and other payments presenting withholding tax risk. Support Upstream activities, including exploration, development, production, joint operating arrangements, production sharing and concession regimes, decommissioning, abandonment obligations, asset swaps, and new country access or expansion projects. Support Downstream activities, including refining, terminals and pipelines, retail, aviation, biofuels, renewable fuels, customer-facing businesses, supply chains, and margin-led commercial models. Coordinate with Tax Operations to ensure tax planning, attributes, elections, transactions, and uncertain tax positions are accurately reflected in bp’s tax filings and financial reporting processes. Lead or support tax audit and controversy workstreams, including strategy development, technical position papers, information document request responses, issue management, and engagement with fiscal authorities. Review and draft tax-related contractual language in commercial agreements, joint venture documents, acquisition and divestment agreements, financing documents, and intercompany arrangements. Analyse proposed legislation, regulations, administrative guidance, and tax policy developments in the US and relevant international jurisdictions, advising Tax leadership and business-facing teams on potential impacts and mitigation strategies. Manage tax risk, efficient operations, standardization and simplification, reduce complexity, and identify continuous improvement opportunities across advisory processes and controls. Coordinate closely with colleagues accountable for Transfer Pricing and advisory support for bp’s Supply, Trading & Shipping (ST&S) business, particularly with respect to intercompany transactions, commodity flows, services, financing, risk allocation, and other commercial activity between bp’s Upstream and Downstream business divisions and ST&S. Work collaboratively with Group Tax, Legal, Finance, and business teams to ensure integrated advice across direct, indirect, transfer pricing, accounting, and commercial considerations. Build and maintain tax playbooks, issue logs, technical memoranda, precedent libraries, and lessons learned to improve consistency, audit readiness, and knowledge sharing across the Tax Americas advisory team. Requirements of the role: Education/Professional Qualifications A post-graduate level degree in tax, accounting, law, economics, finance or another relevant subject area. CPA, attorney, chartered accountant or equivalent professional qualification is preferred. Skills and Experience: Significant, relevant experience in tax advisory, preferably includi