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.