In-House International Tax Counsel

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.