Advising on secondments of both partners and employees, either internationally or into the UK.
Advising on secondment arrangements and consultancy terms to manage tax exposures and permanent establishment risks, involving liaising with both external advisors and in-house lawyers.
Liaising with the firm's overseas offices and tax advisors to resolve uncertain tax positions and address risks.
Ensuring the allocation of profits from the various group entities is undertaken in a tax efficient manner, as well as assisting in the management of the individual partners' double tax relief positions.
Maintaining the firm's transfer pricing policy and reviewing the transfer pricing charges to help coordinate adherence with base erosion and profit-shifting (BEPS).
Managing the firm's exposure to withholding taxes internationally, including analysis of withholding tax recoverability.
Evaluating permanent establishment risks for the firm on an ongoing basis.
Providing US tax support, including working with the firm's advisors and local US office to ensure completion of US tax returns for partners outside of the US, correct completion of withholding tax certificates, and oversee the timely completion of the firm's US tax filings as required.
Providing UK tax support on an ad-hoc basis to the team's UK group tax manager. This may include providing support and analysis for double tax relief claims.
Advising on the tax aspects of group restructuring, and the opening of offices in existing and new jurisdictions.
Please note our advertisements use PQE/salary levels purely as a guide. However we are happy to consider applications from all candidates who are able to demonstrate the skills necessary to fulfil the role.