Manager – International Tax & UAE Structuring – CA Career Click

The Corporate Institute; Abu Dhabi; On-site; AED 180,000 - 300,000; Full time

Job summary

The Corporate Institute in the United Arab Emirates seeks an international tax professional to structure cross-border transactions with a focus on India–UAE and to advise on UAE Corporate Tax positions.

You will read domestic law and the DTAA to determine treatment of dividends, interest, royalties, capital gains and business income, test treaty eligibility, withholding, PE exposure, residence and beneficial ownership, and identify routes to reduced rates.

Qualifications

• 2–3 years in international taxation, cross-border tax advisory or transaction structuring.
• CA or equivalent professional qualification.

Responsibilities

• Structure transactions across multiple jurisdictions with focus on India–UAE.
• Read domestic law and the DTAA to determine treatment of dividends, interest, royalties, capital gains and business income.
• Test treaty eligibility, withholding, PE exposure, residence and beneficial ownership, and identify routes to reduced or nil tax rates.
• Advise on UAE Corporate Tax positions and reliefs, including group relief, restructuring and exemptions.
• Review and sign off Corporate Tax Returns prepared by the compliance team.
• Identify UAE restructuring opportunities including ADGM/DIFC foundations and foundations tax treatment.
• Track new UAE CT developments and assess their effect on client structures.
• Support the India tax structuring team on UAE side of acquisitions, restructurings, holding structures and outbound investment.
• Test structures under FEMA and Indian exchange controls.

Skills

International taxation

Cross-border advisory

Tax structuring

Education

CA or equivalent

Job description

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.