onhires - In-House International Tax Counsel

Europe1w ago

In Office Senior EMEA Cryptocurrency Payments Tax Counsel Accountant Reporting NFTs Documentation

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.

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.