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