International Tax Counsel

About the Position

International Tax Counsel

Our client is an international fintech group providing technology and liquidity solutions to brokers, financial institutions, and digital asset businesses. The group operates through multiple regulated and non-regulated entities across several jurisdictions and manages cross-border structures, intercompany arrangements, technology licensing models, and shareholder distribution flows.

We are looking for an experienced International Tax Counsel to join the Legal & Compliance team and support the group’s international tax matters.

Location: Remote within Europe

Engagement: Full-time, long-term

Contract: B2B Service Agreement

Department: Legal & Compliance

Reports to: Chief Legal Officer

Responsibilities

International Tax Advisory and Risk

• Assess international tax exposure across existing and prospective jurisdictions.
• Identify permanent establishment, treaty residency, economic substance, hybrid mismatch, and anti-avoidance risks.
• Support the maintenance of the group tax risk register and recommend mitigation actions.
• Assess how management, operational substance, and regulated entity activities affect the group’s tax positions.
• Advise on restructurings, new jurisdiction entries, entity mergers, wind-downs, and ownership changes.
• Monitor relevant developments, including BEPS Pillar Two, ATAD I and II, DAC6, FATCA/CRS, and local anti-avoidance legislation.
• Prepare clear tax recommendations and briefings for internal stakeholders.

Transfer Pricing and Intercompany Arrangements

• Support the development and maintenance of the group’s transfer pricing framework.
• Advise on management services, technology and platform access, IP licensing, administrative services, treasury lending, and other intragroup transactions.
• Review intercompany agreements and help ensure consistent pricing and service characterisation.
• Support transfer pricing documentation, including Master File, Local Files, and Country-by-Country Reporting where applicable.
• Coordinate jurisdiction-specific documentation and filings with external advisers.
• Support responses to tax authority queries and transfer pricing audits.

VAT and Indirect Tax

• Advise on VAT, GST, and equivalent indirect tax obligations across regulated and non-regulated entities.
• Analyse the VAT treatment of financial services, electronic money products, technology licensing, digital services, and crypto-related activities.
• Apply financial services exemptions and place-of-supply rules across the EU, UK, UAE, and other relevant jurisdictions.
• Advise on input VAT recovery and partial exemption matters.
• Monitor VAT registration, filing, and payment obligations.
• Assess the VAT implications of new products, business models, and geographic expansion.

Dividends and Cross-Border Payments

• Assess withholding tax exposure on dividend distributions and other cross-border payments.
• Analyse access to treaty relief, beneficial ownership requirements, and economic substance considerations.
• Support the review of holding structures and profit repatriation arrangements.
• Evaluate cash extraction alternatives, including management fees, royalties, intercompany loans, interest, dividends, and return-of-capital mechanisms.
• Advise on shareholder loans, convertible instruments, and equity-linked arrangements.
• Support the assessment of exit tax and deemed distribution consequences.

Corporate Tax Compliance Oversight

• Coordinate the group’s corporate income tax compliance calendar across active jurisdictions.
• Work with local finance teams and external tax advisers to ensure timely and accurate filing and payment.
• Review tax returns and calculations for material entities.
• Support tax-related audit and financial statement matters, including IAS 12, deferred tax, uncertain tax positions, and contingent liabilities.
• Assist with maintaining the group tax policy and jurisdiction-level effective tax rate model.
• Escalate material tax risks and discrepancies to senior stakeholders.

Regulatory and Cross-Functional Coordination

• Help ensure that tax positions are consistent with regulatory capital, licence conditions, distribution restrictions, and profit-repatriation requirements.
• Work with legal, compliance, finance, corporate development, and external advisers.
• Advise on the tax structuring of partnerships, white-label arrangements, revenue-sharing agreements, and investment relationships.
• Assess the tax implications of regulatory-driven restructurings and reporting changes.

Requirements

• Qualified lawyer, Chartered Tax Adviser, or holder of an equivalent recognised tax qualification.
• At least seven years of international tax experience, ideally post-qualification.
• Experience advising or working with multi-entity international groups and cross-border structures.
• Strong working knowledge of the OECD Transfer Pricing Guidelines, BEPS Actions, and Pillar Two GloBE rules.
• Practical experience interpreting double tax treaties and assessing permanent establishment, residency, substance, and withholding tax positions.
• Hands-on VAT experience in at least two of the following: EU member states, UK, or UAE.
• Experience with financial services VAT exemptions or cross-border digital service classification.
• Ability to coordinate and challenge external tax advisers across multiple jurisdictions.
• Strong organisational skills and ability to manage several workstreams independently.
• Excellent written and spoken English.

Preferred Background

• Previous in-house or advisory experience within fintech, payments, electronic money, financial services, digital assets, or another regulated international business.
• Experience with transfer pricing, technology licensing, or financial services VAT.
• Familiarity with UAE, Cyprus, Mauritius, Seychelles, and/or UK treaty networks.
• Exposure to VARA, DFSA, CySEC, FSC, FCA, or comparable regulated environments.
• Experience with economic substance requirements in low-tax or offshore jurisdictions.
• Knowledge of crypto and digital asset tax matters.
• Exposure to financial instruments such as CFDs, total return swaps, convertible loans, or repo arrangements.
• Familiarity with FATCA/CRS obligations for financial institutions.

We Offer

• Broad exposure to international tax and cross-border structuring matters.
• Direct collaboration with the CLO, finance, legal, compliance, and senior management.
• Opportunity to develop wider in-house tax ownership.
• Autonomous work within an international fintech environment.
• Long-term remote B2B cooperation.

About the Company

Our client is an international fintech group providing technology and liquidity solutions to brokers, financial institutions, and digital asset businesses. The group operates through multiple regulated and non-regulated entities across several jurisdictions and manages cross-border structures, intercompany arrangements, technology licensing models, and shareholder distribution flows.