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Senior Manager / Associate Director - UK Corporate Tax - Real Estate
Talent IntegratorsGurugram, India30+ days ago
Job descriptionAnalyze interest deductibility in relation to : Transfer pricing (TP) adjustments Unallowable purpose rules Anti-hybrid rules Late payment restrictions 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 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 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) 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
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 :
3. Real Estate Structures & Taxation :
4. Non-Resident Capital Gains Tax (NRCGT) :
5. Capital Allowances & Group Taxation :
Advisory & Client Support :
Budget- 19-27 L for Sr. Manager, 27-35 L for Associate Director
ref : iimjobs.com)
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Senior Tax Tax • Gurugram, India
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