Manager - International Tax & UAE Structuring - CA

Responsibilities:

• Structure transactions across two or more jurisdictions, with a focus on India - UAE.
• Read domestic law and the applicable DTAA together to determine treatment of dividends, interest, royalties, capital gains and business income.
• Test treaty eligibility, withholding, PE exposure, residence and beneficial ownership, and identify legitimate routes to a reduced or nil rate.
• Advise on UAE Corporate Tax positions and reliefs: Qualifying Group Relief, Business Restructuring Relief, Participation Exemption, Tax Groups, Tax Losses, Free Zone and mainland structures, Small Business Relief and tax transparent structures.
• Recommend which regime a client should sit in on its facts.
• Review and sign off Corporate Tax Returns prepared by the compliance team, including the positions taken, the reliefs claimed and the disclosures made to the FTA.
• This is a core part of the role, not an occasional escalation.
• Identify UAE restructuring opportunities, including conversion of LLC ownership into ADGM or DIFC Foundation structures for succession, family wealth, asset and creditor protection, and evaluate tax transparent treatment for Foundations.
• Track new UAE CT developments and assess their effect on existing client structures.
• Support the India tax structuring team on the UAE side of acquisitions, business transfers, restructurings, holding structures, outbound investment and exits.
• Test whether a proposed structure is implementable under FEMA and Indian exchange control, and identify constraints on outbound investment, overseas holding companies and Foundations.

Ideal Profile:

• 2 - 3 years in international taxation, cross-border tax advisory or transaction structuring.
• CA or equivalent professional qualification.