Continuously map tax exposure, including permanent establishment, treaty positions and anti-avoidance; maintain a risk register and brief the CLO/CFO.
Build a defensible transfer-pricing framework for all intragroup transactions, including licensing of a proprietary technology platform; prepare Master File and Local Files documentation in line with OECD Guidelines.
Conduct place-of-supply analysis for digital services and handle financial-services exemptions for UAE, EU and UK VAT.
Optimise withholding tax on dividends and evaluate free-cash-flow extraction strategies, including management fees and royalty flows.
Requirements
Qualified lawyer or chartered tax adviser (CTA, ADIT).
Minimum 7 years’ practical experience in multi-entity structures in fintech, payments or digital assets.
Genuine experience with high-risk industries and strong knowledge of crypto.
Able to work autonomously as a single contributor and produce clear memoranda for a non-tax audience.