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.