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Senior Manager / Associate Director - UK Corporate Tax - Real Estate

Senior Manager / Associate Director - UK Corporate Tax - Real Estate

Talent IntegratorsBangalore, India
30+ days ago
Job description

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

    ref : iimjobs.com)

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    Senior Tax Tax • Bangalore, India