Overview

Location – Bangalore/Gurgaon (hybrid)

Experience- 6-12 Years

Job Description

Key Responsibilities:

1. Corporate Interest Restriction (CIR):

– Interpret and apply key CIR concepts including:

– Definition and assessment of groups

– Calculation and application of the Group Ratio Rule (GRR) and Fixed Ratio Rule (FRR)

– Application of de minimis thresholds and the debt cap

– Assessment and impact of Public Benefit Infrastructure Exemption (PBIE) elections

– Compliance and administrative requirements

2. Other Interest Restrictions:

– Analyze interest deductibility in relation to:

– Transfer pricing (TP) adjustments

– Unallowable purpose rules

– Anti-hybrid rules

– Late payment restrictions

3. Real Estate Structures & Taxation:

– Advise on tax implications of various real estate investment structures, including:

– Fund structures, partnerships, JPUTs (Jersey Property Unit Trusts), and REITs (Real Estate Investment Trusts)

– Comparison of UK vs. non-UK holding companies for UK real estate investments

– Provide structuring advice on acquisitions, disposals, and reorganizations

4. Non-Resident Capital Gains Tax (NRCGT):

– Understand and apply NRCGT principles including:

– Identification of UK property-rich companies

– Treatment of latent gains

– Scope of UK taxation for non-UK residents on share disposals

– Application and consequences of exemption and transparency elections

5. Capital Allowances & Group Taxation:

– Advise on capital allowance claims within property structures

– Apply group tax principles, including:

– Nil gain/nil loss transfers

– Degrouping charges

– Group relief claims and restrictions

– Loss relief (carry forward, carry back, and restrictions)

Advisory & Client Support:

– Provide tax structuring advice on property acquisitions and disposals

– Deliver cross-border tax advice and conduct due diligence for international transactions

– Assist clients in establishing tax-efficient property fund structures, including UK REITs

– Support clients with deferred tax accounting for complex real estate groups

– Provide specialist input on CIR, anti-hybrid, transfer pricing, and group relief interactions

– Participate in client pitches, proposal preparation, and other business development activities

Budget- 19-27 L for Sr. Manager, 27-35 L for Associate Director