Corporate Tax
Manager, International Tax and UAE Structuring (India)
The same role, based with the India team and working on the UAE side of India-UAE mandates.
India1 openingFull time
- Practice
- Corporate Tax
- Location
- India
- Experience
- 2 to 3 years
- Qualification
- CA or equivalent
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.
- Take a recommended structure through to implementation by coordinating with the corporate service provider or registered agent on incorporation of UAE entities: select the vehicle and jurisdiction, brief the agent, resolve the tax and licensing questions that arise, and see it through to set-up. Knowledge of the incorporation procedure itself is not required.
- 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.
Essential
- 2 to 3 years in international taxation, cross-border tax advisory or transaction structuring.
- Ability to read a tax treaty alongside domestic law and reach a defensible position independently.
- Ability to work from primary sources: legislation, treaties, Cabinet and Ministerial Decisions, and administrative guidance.
- Ability to produce more than one workable structure for a transaction and explain the trade-offs.
- Working knowledge of UAE Corporate Tax, or demonstrated ability to build technical depth in a new regime quickly.
- CA or equivalent professional qualification.
Preferred experience
- FEMA and Indian exchange control regulations, and Indian international tax provisions.
- ADGM and DIFC Foundations, succession and private client structuring.
- M&A tax, due diligence and corporate restructuring.
- Experience coordinating UAE entity incorporations with service providers.
- Depth in UAE CT return review.
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