In-House International Tax Counsel

OnHiresOn-siteFull-timeSenior, 5–8 yearsListed 2 months ago

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About this role

Type: Full-time, Permanent
Format: Remote
Contract: B2B
Reports to: CLO

🔎 Role Overview

We are seeking an experienced In-House International Tax Counsel for our client — a global fintech company providing technology solutions and liquidity services to brokers, financial institutions, and crypto exchanges.

This is a senior individual contributor role, responsible for the full cycle of international tax risk management: from strategy and analysis to compliance oversight and regulatory coordination.

📌 Key Responsibilities

1. International Tax Strategy

- Assess and map tax risks across multiple jurisdictions.
- Maintain a group tax risk register and brief CLO/CFO regularly.
- Monitor BEPS, ATAD, DAC6, FATCA/CRS and local legislative changes.
- Advise on restructurings, new market entries, and ownership changes.

2. Transfer Pricing & Intercompany Agreements

- Develop and maintain a defensible transfer pricing framework.
- Prepare Master File, Local Files, and CbCR documentation.
- Review and align intercompany agreements.
- Defend positions in audits and manage MAP procedures.

3. VAT & Indirect Tax

- Advise on VAT/GST for financial and technology products.
- Analyze place-of-supply rules for digital services.
- Oversee VAT registrations and filings in EU, UK, UAE.
- Evaluate VAT implications of new products and business models.

4. Dividends & Shareholder Planning

- Assess withholding tax on dividend flows and treaty relief.
- Optimize holding structures considering substance requirements.
- Model cash extraction strategies (fees, royalties, loans).
- Advise on shareholder loans and convertible instruments.

5. Corporate Tax Compliance

- Coordinate tax filing calendars across jurisdictions.
- Review returns and challenge external advisers where needed.
- Support audits (IAS 12/IFRS disclosures).
- Maintain group tax policy and effective tax rate models.

6. Regulatory & Cross-Functional Coordination

- Align tax positions with licensing and capital requirements.
- Advise CLO on new regulatory obligations.
- Support corporate finance and BD in structuring partnerships.

👤 Candidate Requirements

- Qualified lawyer or Chartered Tax Adviser (CTA, TEP, ADIT).
- 7+ years of international tax experience.
- Strong knowledge of OECD TP Guidelines, BEPS, Pillar Two.
- Experience with double tax treaties (UAE, Cyprus, Mauritius, UK).
- VAT expertise in at least two jurisdictions (EU, UK, UAE).
- Proven ability to manage external advisers across countries.
- Highly organized, self-directed, able to manage multiple workstreams.
- English: C1 / Fluent level.
- Excellent written communication skills for clear, structured memoranda.

⭐ Preferred Background

- In-house experience in financial institutions, payment/EMI, or digital assets.
- Familiarity with regulatory environments (CySEC, MFSA, FCA, VARA, DFSA).
- Experience with crypto taxation (tokens, DeFi, staking, NFTs).
- Knowledge of economic substance and TP in low-tax jurisdictions.
- Exposure to financial instruments (CFDs, TRS, repo).
- FATCA/CRS reporting for financial institutions.