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.