We are seeking an experienced and commercially minded Deputy Director, Tax Structuring to lead tax structuring and advisory initiatives across the Group's data center investments, developments, operations, and expansion activities.
About the Role
The successful candidate will be responsible for developing and implementing tax-efficient and commercially sustainable structures for cross-border investments, acquisitions, financing arrangements, data center developments, and business operations. This role will work closely with senior management, Finance, Legal, Treasury, Investment, and business teams, as well as external tax advisors.
Responsibilities
Tax Structuring & Planning
- Lead tax structuring initiatives for new data center investments, developments, acquisitions, and business expansion.
- Develop tax-efficient structures for cross-border investments and operating models while ensuring compliance with applicable tax laws and regulations.
- Assess tax implications of different investment, holding, financing, and operating structures.
- Provide strategic tax advice to senior management on major business and investment decisions.
- Monitor changes in international and local tax regulations and assess their impact on the Group.
M&A and Investment Transactions
- Provide tax structuring and due diligence support for M&A, joint ventures, investments, divestments, and corporate restructuring.
- Review transaction structures, SPA/JV agreements, financing arrangements, and other transaction documents from a tax perspective.
- Identify tax risks and opportunities and develop appropriate mitigation strategies.
- Work closely with Investment, Legal, Finance, and external advisors throughout the transaction lifecycle.
International & Cross-Border Tax
- Advise on cross-border tax matters involving multiple jurisdictions.
- Manage tax considerations relating to holding companies, financing structures, withholding taxes, permanent establishment, transfer pricing, and repatriation of profits.
- Support the Group's international expansion and new market entry strategies.
- Ensure tax structures remain aligned with international tax developments.
Data Center Development & Operations
- Provide tax advice on the development and operation of data centers, including land acquisition, construction, equipment procurement, financing, and operating arrangements.
- Evaluate tax implications of capital expenditure, depreciation, incentives, leases, service arrangements, and intercompany transactions.
- Support the business in identifying and evaluating tax incentives, grants, and investment incentives available in relevant jurisdictions.
- Work closely with the transfer pricing team/advisors to develop appropriate and commercially supportable intercompany arrangements.
- Review related-party transactions and ensure appropriate tax treatment and documentation.
- Support tax audits, tax authority inquiries, and dispute resolution relating to structuring matters.
Stakeholder Management
- Partner with senior management and cross-functional teams including Financial Controllership, Treasury, Capital Markets, Legal, Investment, Delivery, and Operations.
- Manage relationships with external tax advisors, legal counsel, and relevant tax authorities.
- Present complex tax matters and recommendations clearly to senior management and stakeholders.
Qualifications
- Bachelor's degree in Accounting, Finance, Tax, Law, or a related discipline.
- Professional tax/accounting qualification such as CTA, ACCA, CA, CPA, or equivalent is preferred.
- Typically 10–13 years of relevant tax experience, with substantial experience in international tax and tax structuring.
- Strong experience in cross-border tax planning, M&A, investment structuring, corporate restructuring, and international taxation.
- Experience working in Big Four is required.
- Experience across multiple jurisdictions, particularly in Asia-Pacific, is required.
- Strong understanding of corporate income tax, withholding tax, transfer pricing, tax treaties, indirect taxes, and international tax developments.
- Strong commercial acumen with the ability to balance tax efficiency, business objectives, financing flexibility, regulatory requirements, and risk.
- Excellent communication, negotiation, analytical, and stakeholder management skills.
- Ability to work independently and manage multiple complex projects in a fast-paced environment.