Our client is a leading Big 4 with a strong Financial Services Tax Team that have a need within their Tax Structuring Department. They are looking for a Senior Manager or Director from another Big 4 or coming back from industry who wished to join a team that is quickly capturing market share from their competitors. They offer rapid promotion prospects due to their expansion plans so if you feel you are ready for promotion they can offer you this.
You will develop a knowledge of tax law in respect of loan relationships and relevant non-lending relationships (e.g. repos, disguised interest, shares accounted for as liabilities), derivative contracts, equity instruments, double tax relief, controlled foreign companies, distribution exemption and relevant anti-avoidance provisions such as unallowable purpose, transactions in securities and avoidance involving arbitrage. You will further get involved in developing and implementing a variety of cross-border financing structures, CFC protection structures and domestic tax planning structures utilising non-resident entities. There will be International tax advisory work including planning for controlled foreign companies and reviews of controlled foreign companies, DTR, WHT in various jurisdictions and associated treaty analysis.
Pro-Tax is the UK's market leader in the recruitment of tax professionals to both practice and commercial clients. We recruit at all levels from Tax Assistants to Partners and Heads of Tax on a national and international basis. Whether you are looking for a new role or similarly looking to recruit high calibre staff, contacting Pro-Tax should be your first move.