International Tax & M&A Consultant

Lorien

International Tax & M&A Consultant
6 months – 12 Months
Hybrid working (Farringdon)
Inside IR35

My client a top Global company are currently looking to recruit an International Tax & M&A Consultant to join their team on a contract basis. Please note if successful contracts will need to be set up via an Umbrella Company/PAYE. The International Tax & M&A Consultant will be responsible for supporting our client’s divestment and legal entity rationalisation programme while also assisting with corporate development activities, including acquisitions. The International Tax & M&A Consultant role will manage international tax and transfer pricing queries, ensuring compliance and efficiency in line with Global Tax policies. The ideal candidate will have experience in international tax, M&A, transfer pricing; and cross-border structuring, collaborating closely with the Group Tax, Legal, Finance, and Corporate Development teams.

Main Duties and Responsibilities for the International Tax & M&A Consultant:

• Divestments and Rationalisation:
  • Support Group Legal with time-sensitive legal entity rationalisation initiative, to ensure tax compliant liquidations/mergers or repurposing of surplus Group entities in various jurisdictions.
  • Support the Group Corporate Development team in finalising the post-sale process of various divestments including deal fee deductibility reviews, support with obtaining VAT refunds where applicable, tax accounting and reporting compliance, and review of tax return entries with UK, US and overseas tax compliance teams.
  • Collaborate with Finance, Legal and Treasury teams to execute the legal and financial aspects of entity closures, transfers, reorganisations and cash repatriation processes, in particular providing guidance and structure to tax compliant dividend payments.
• Corporate Development and Acquisitions:
  • Provide tax support on new acquisitions and other corporate development projects, including due diligence and post-acquisition integration.
  • Analyse tax risks and opportunities associated with potential acquisitions, further divestments and restructurings.
  • Assist in the preparation and review of tax clauses in Share Purchase Agreements (SPAs) and related legal documents.
  • Support tax set up of new legal entities where required.
• Pillar 2 and Restructuring:
  • Lead a restructuring review of the Group’s Captive Insurance entity in Bermuda, to ensure Pillar 2 Compliance costs, and other associated tax risks are mitigated and managed practically moving forward.
  • Provide guidance and support to ensure that new Pillar 2 rules implemented continue to offer an attractive foreign direct investment proposition.
  • Support with Board Meetings
• International Tax and Transfer Pricing:
  • Address ad hoc international tax and transfer pricing queries from the business.
  • Support in the preparation and review of transfer pricing documentation and policies to ensure compliance with OECD guidelines and local regulations.
  • In particular, support your line manager with the Group’s UK Local Files for FY24 and help implementing a more formal global transfer pricing documentation process to close compliance gap and move into a new TPD Operating Model.
  • Assist in the review of intercompany agreements, ensuring they reflect accurate commercial and tax positions and project manage their delivery.
  • Help identify territories for which R&D credits, or other tax incentives, and project manage advisory engagements
• Reporting and Compliance:
  • Support the Tax Ops team with international tax reporting requirements, including Controlled Foreign Corporation (CFC) and Permanent Establishment (PE) analyses.
  • Support with update to the Group’s IFRIC 23 International Direct Tax provision.

Qualifications & Experience for the International Tax & M&A Consultant

• Qualifications:
  • ACA/ACCA, CTA, or equivalent professional qualification.
• Experience:
  • Significant experience in international tax, including divestments, M&A, and transfer pricing.
  • Experience with legal entity rationalisations and cross-border restructurings.
  • Knowledge of international tax principles, OECD guidelines, and transfer pricing regulations would be helpful.
  • Ideally some exposure to US Direct Tax obligations and principles.
• Skills:
  • Analytical skills with attention to detail.
  • Excellent communication and collaboration skills, with the ability to work across Tax, Finance, Legal, Treasury and Corporate Development teams.
  • Proficiency in Microsoft Office tools.
  • Ability to manage multiple projects and deadlines in a dynamic environment.

Carbon60, Lorien & SRG – The Impellam Group STEM Portfolio are acting as an Employment Business in relation to this vacancy.