In-House Property Tax Manager

This household name financial services business are currently looking to recruit a Property Tax Manager.

Your new role

    • Provide practical tax support to the Real Assets team (fund/asset managers, transaction team, property directors and finance business partners) on ad-hoc queries and be a property tax subject matter expert to group tax colleagues. E.g. non-resident landlord, leasing and financing transactions, restructuring, property development, company liquidations, stamp duty land tax and capital allowances;
    • Provide end to end tax support and risk management, i.e. from the structuring of fund or holding entities on behalf of investor(s), to the financing and acquisition of properties or property-rich structures, to the on-going property holding or asset management (e.g. property development or conversion), to the post acquisition restructuring, and eventual exit of the underlying investments as further elaborated below;
    • Support Property Business Development team on new product launches;
    • Work with internal colleagues and external advisors to structure property or property SPV acquisitions. This includes consideration of transaction tax issues (SDLT, LBTT, LTT, VAT), tax residence and PE, inherent gains, future use of property (investment vs build to rent vs develop to sell), direct tax issues, financing, transfer pricing and withholding tax;
    • Review external advisors' tax due diligence reports and manage risks within Sale and Purchase agreements' warranties/indemnities drafting and purchase price negotiations;
    • Ensure that the tax risks inherited and structures adopted are within the Group's tax policy;
    • Ensure that appropriate risk management controls / procedures are in place to manage all property tax risks (including those inherited from acquired structures) on an ongoing basis;
    • Ensure that relevant colleagues or external advisors are tee'd up to submit any post acquisition tax elections / returns on time. This includes VAT registration and option to tax, capital allowance election, SDLT / LBTT / LTT returns, etc;
    • Ongoing tax oversight of the range of funds and vehicles (limited partnerships, property unit trusts, joint venture companies and asset holding companies set up in the UK, Jersey, Luxembourg and Netherlands). This includes creating/reviewing procedure notes and ensuring compliance with direct tax, withholding tax, FATCA, construction industry scheme and ATED;
    • Prepare and collate documentation to support board decisions and tax filing positions relating to property transactions;
    • Ensure processes are followed so that the expected tax treatments identified at transaction stage are reflected in tax computations and returns;
    • Review quarterly and annual direct tax information relating to Group companies' ownership of underlying properties / funds before providing to Group;
    • Provide tax provisions of the property companies to Group Tax usually on a semi-annual basis;

What you'll need to succeed

Professional Accounting Qualification (e.g. ACA or ACCA) and/or Taxation qualification (e.g. CTA) with a solid level of post qualification property tax experience within a large corporate or practice. Additonally:

  • Good understanding of UK authorised and unauthorised property funds commonly used, including limited partnerships, property unit trusts, PAIFs, ACSs;
  • Good understanding of tax implications, risks and efficiencies relevant to property fund set ups, including tax transparency vs opaque for direct tax and CGT, non-resident landlord requirements and withholding tax on rents, sovereign immunity, CFC and section 13 TCGA 1992 issues;
  • Practical experience of real estate funds' property / SPV acquisition, holding and eventual disposal (especially income tax, corporation tax, SDLT, capital allowances, and the construction industry scheme with some knowledge of VAT);
  • Good understanding of the mechanics and accounting of commercial and residential property



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