The person we are looking for should, ideally, have all the following qualities:
-10+ years experience of International Tax planning from a Private Client background. This covering both advising individuals and their companies on International Tax matters.
-Proven success in building and managing a tax practice. Motivational skills.
-Detailed technical knowledge and the practical applications of:
Essential
1. Domestic residence and domicile rules in the UK and other European countries.
2. Tax and estate planning for High Net Worth Individuals (HNWIs) through the use of trusts, life insurance wrappers, companies and other legal forms.
3. The uses of offshore finance centres in international structuring.
4. UK anti-avoidance legislation, with a working knowledge of other countries’ anti-avoidance measures (i.e. fiscal transparency, controlled foreign company provisions, management and control, permanent establishments, transfer pricing etc.).
5. Staff incentive arrangements (e.g. EBTs and share option schemes) and pension schemes.
6. Double Tax Treaties especially entitlement to treaty benefits, residence and the tie-breaker article, business profits and capital gains articles etc.
7. Structuring cross-border transactions in immovable property.
Desirable
8. European Holding Company regimes and the EU Directives on Tax.
9. Separating and relocating Intellectual Property.
10. Financing Structures.
11. Experience of dealing directly with tax authorities
12. Good interpersonal skills and public speaking and writing ability
PROFESSIONAL QUALIFICATIONS
Ideally CTA qualified, but could be a Chartered Accountant or Tax Lawyer. Could possibly be qualified by experience, but the case would need to be exceptional. Membership of STEP would be an advantage.
ROLE
The following is a non-exhaustive list of the responsibilities of the appointee:
-To build and manage / coach the International Tax team and to ensure that all staff continue to meet the highest technical and service level standards.
-To build an acknowledged “Centre of Excellence” for International Tax planning for High Net Worth Individuals and their entrepreneurial business activities within the Group.
-To promote the Centre of Excellence both within the local market and throughout the Group of Companies and international network.
-To become an expert on all aspects of Gibraltar taxation and apply these features in the area of international taxation and, occasionally, locally.
-To personally provide tax planning advice for the more complex clients (new and existing), liaising, if appropriate, with other overseas offices. Ensuring that any tax compliance matters arising from the advice are dealt with.
-To liaise with the Trust and Company Management team and Pension Administration team in the establishment, implementation and subsequent monitoring and administration of managed structures.
-Co-ordination of structures involving several overseas offices.
-To carry out “four eyes” reviews of tax planning/advisory reports, discussion documents, etc that are issued by the tax planning team.
-To develop “Tax Planning Ideas” (TPIs) relating to Gibraltar and the use of offshore structures generally and to communicate these to interested parties, including clients and intermediaries.
-To assist with internal training, both within the tax team (technical) and the Group (tax awareness) and point tax planning staff to relevant external training.
-To be involved in the marketing of the Group to include, but not limited to, website contributions, articles, propriety research, arranging seminars and the development of relationships with existing and new professional intermediaries, to increase the awareness of the Group’s tax abilities
-To develop areas of personal expertise which are complimentary to the objectives of the Group
-To assist, where required, with special projects that do not naturally fit into the scope of any other Group Company.
-To ensure tax division budgeted productivity, billing and cash collection targets are achieved/exceeded.
PERSONAL ATTRIBUTES
Although far from cast in stone, the sort of person we envisage would be attracted by this opportunity is likely to be:
-Prepared to commit for a minimum of five years (and hopefully a lifetime !).
-Used to (or could adapt to) working in a small team. Sociable.
-Proactive, lateral thinker / planner.
-Enthusiastic; leader; excellent communicator; good “bedside” manner with clients.
-Looking for quality of life, but doesn’t want to give up work.
-Self and spouse / family used to the expatriate way of life. Not dependent on big city culture/entertainment for social fulfilment.
-Enjoy outdoor sports / pastimes.
-Ideally has some language skills (Spanish and/or French).
We are a niche consultancy offering recruitment and other peripheral services to tax professionals. In particular we are known in the market for relocating experienced tax specialists cross-border.
If you decide to contact us you can be assured of absolute confidentiality, an efficient and friendly service and straight-talking advice.
Dorifor Tax Group - our portfolio of tax sites:
