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.