Tax Manager

Entity

Finance

Job Family Group:
Tax Group

Job Description:

Provide tax support on US domestic and international tax matters relating to bp’s Upstream and Downstream businesses, working under the direction of senior Tax Americas colleagues.

Collaborate with business and functional partners across Upstream, Downstream, Finance, Legal, Tax Operations, Transfer Pricing, Indirect Tax, Treasury, Policy, and other Group Tax teams to provide practical, commercially aligned tax input and raise complex or material matters appropriately!

This role will support tax planning, compliance, audit and appeals, and tax policy matters relating to bp’s US and cross-border Upstream and Downstream activities, including investments, restructurings, divestments, joint ventures, financing arrangements, supply chains, and operating model changes.

Key Accountabilities

• Support senior Tax Americas colleagues in helping ensure that Upstream and Downstream business activities are conducted in compliance with applicable federal, state and municipal and relevant international tax rules and principles.

• Provide timely and practical tax input on investments, commercial arrangements, operating model changes, supply chains, restructurings, joint ventures, acquisitions, divestments, farm-ins, farm-outs, and other business initiatives, raising novel, complex, or material issues as appropriate.

• Support analysis of US domestic tax matters including corporate taxation (inclusive of the US Corporate Alternative Minimum Tax regime), consolidated return principles, partnership taxation, tax accounting methods, federal credits and incentives (primarily general business credit regimes), withholding, information reporting, and the tax treatment of financing, hedging, commodity, and commercial arrangements.

• Support analysis of international tax matters including subpart F, GILTI/NICTI, foreign tax credits, sourcing, treaty matters, permanent establishment risk, cross-border reorganizations, withholding taxes, branch and disregarded entity considerations, and inbound and outbound investment structures.

• Coordinate with Treasury, Transfer Pricing, Legal, Tax Operations, and regional tax teams to support funding structures that are commercially effective, tax efficient, aligned with arm’s-length principles, appropriately documented, and accurately reflected in tax filings and financial reporting.

• Provide tax advisory support for 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.

• Provide tax advisory support for 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 support accurate reflection of tax planning, attributes, elections, transactions, and uncertain tax positions in bp’s tax filings and financial reporting processes.

• Support tax audit and controversy workstreams, including technical research, position paper drafting, information document request responses, issue tracking, and preparation for engagement with fiscal authorities.

• Review and provide input on tax-related contractual language in commercial agreements, joint venture documents, acquisition and divestment agreements, financing documents, and intercompany arrangements, with senior review for significant matters.

• Monitor and analyse proposed legislation, regulations, administrative guidance, and tax policy developments in the US and relevant international jurisdictions, preparing summaries and recommendations for senior Tax colleagues and business-facing teams.

• Support tax risk management, efficient operations, standardization and simplification, and 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 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 Supply, Trading & Shipping.

• Work collaboratively with Gorup Tax, Legal, Finance, and business teams to support multidisciplinary 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.

• Continue to develop expertise in priority technical tax areas and maintain awareness of emerging tax, commercial, and regulatory developments affecting bp's businesses.

Key Challenges

• Work with business personnel and source data where tax requirements may not be primary to the commercial, operational, or project objective, while identifying issues that require senior review.

• Coordinate input from multiple businesses, functions, and jurisdictions, including Upstream and Downstream teams with different operating models, risk profiles, and decision timelines.

• Develop tax analyses and recommendations based on incomplete or imperfect source data, documenting key assumptions, sensitivities, and evidence needed to support tax positions.

• Build expertise in areas where tax law, fiscal policy, energy policy, and commercial structures continue to evolve, applying technical research and commercial judgment under appropriate supervision.

• Support the balancing of tax optimization, compliance, audit defensibility, reputation, and risk appetite in connection with business decisions.

• Provide practical tax input on transactions, commercial documents, operating decisions, and tax authority matters within compressed timeframes, raising complex or high-risk matters as needed.

Experience and Expertise

• Graduate degree or equivalent experience in tax, accounting, law, economics, finance or other relevant field strongly preferred. CPA, attorney, chartered accountant or equivalent professional qualification preferred.

• 5–8 years of relevant tax experience, preferably including exposure to US federal income tax, international tax, energy sector tax matters, transactions, audit controversy, compliance, or in-house business advisory support.

• Technical Expertise :

• Solid technical knowledge of US federal income tax laws as applied to corporations, consolidated groups, partnerships, joint ventures, transactions, financing, tax accounting, credits and incentives, and international operations, with the ability to research and develop supportable positions under senior guidance.

• Solid understanding of international tax concepts, including foreign tax credits, subpart F, sourcing, GILTI/NICTI, withholding taxes, treaty matters, permanent establishment risk, cross-border reorganizations, and inbound and outbound investment structures.

• Understanding of Upstream and Downstream energy businesses, including key tax attributes, commercial models, contractual frameworks, fiscal regimes, supply chains, operating assets, and transaction lifecycles.

• Solid understanding of US Upstream tax concepts, including intangible drilling costs, tangible drilling costs, geological and geophysical costs, lease acquisition and delay rental costs, dry hole costs, well completion costs, depreciation, capitalization, and cost recovery rules applicable across the exploration, development, production, and abandonment lifecycle.

• Solid understanding of material US Downstream tax issues, including tax depreciation and capitalization for refineries, terminals, pipelines, retail and logistics assets; tax accounting method considerations; repairs, maintenance, turn